at the annual rate of 12%, capitalised monthly from February 2015 until the date of full compliance with the Court's decision; vi. Order the Respondent State to pay him the sum of Two Hundred and Fifty Million (250,000,000) CFA Francs as reparation for moral damage; vii. Order the Respondent State to pay the Applicant’s legal fees for the exercise of the rights of the defence in Benin and before this Court, as well as the costs incurred in respect of documents and of proceedings, upon submission of supporting documents; viii. Order the Respondent State, in view of its failure to comply with previous decisions of the Court, to pay lump sum interest on the award in the amount of Three Hundred Million (300.000.000) CFA Francs per month for failure to comply with the Court’s decision, from the date of notification of the said decision until the Respondent State has fully complied with the said decision; ix. Order the Respondent State to pay costs. 13. For its part, the Respondent State prays the Court to: V. i. Declare that it lacks jurisdiction; ii. Declare the Application inadmissible; iii. Find that all the Applicant's claims are unfounded; iv. Dismiss all the Applicant’s claims and order him to pay costs. JURISDICTION 14. Article 3(1) of the Protocol provides: i. The jurisdiction of the Court shall extend to all cases and disputes submitted to it concerning the interpretation and application of the Charter, this Protocol and any other relevant Human Rights instruments ratified by the State concerned. ii. ln the event of a dispute as to whether the Court has jurisdiction, the Court shall decide. 6

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