i. Declare that it has jurisdiction; ii. Declare the Application admissible; iii. Find that the Government of Benin did not protect its citizens during the demonstrations before and after the 28 April 2019 elections; iv. Declare that Assouma MAMA SEÏDOU was the subject of extrajudicial execution by the Beninese army and that the Government of Benin is liable for his murder; v. Find that the State of Benin violated Assouma MAMA SEÏDOU’s right to demonstrate; vi. Find that the crime of unarmed assembly is a measure restricting the freedom of peaceful public assembly and demonstration; vii. Order the Respondent State to stop deploying the army during public demonstrations in peaceful gatherings; viii. Order the State of Benin to institute serious and necessary proceedings against its employees, members of the armed forces involved in the murder of Assouma MAMA SEÏDOU; ix. Order the State of Benin to repeal the Law on the Penal Code with regard to the offence of unarmed assembly; x. Order the State of Benin to release all those arrested and imprisoned during and in connection with the events relating to the 28 April 2019; xi. Order the State of Benin to report to the Court within such period as the Court may determine; xii. Order the Republic of Benin to pay the sum of Two Hundred Million (200,000,000) CFA Francs as damages; xiii. Order the Republic of Benin to pay costs. 11. The Respondent State prays the Court to: i. Note that the matter was referred to the Court at the initiative of Samiratou MAMA SEÏDOU; ii. Note that she has not been designated by the family or by court order to represent the family; iii. Find that she does not have the power to act before the Court; iv. Note that at the time of considering the Application, local remedies had not been exhausted before Ms Samiratou MAMA SEÏDOU referred the matter to the Court; 4