3. SUBJECT MATTER OF THE PROCEEDINGS: i. Violation of Plaintiffs fundamental rights to life and dignity of human person guaranteed under S.33 and S.34 of the Constitutions of the Federal Republic of Nigeria and Articles 4 and 5 of the African Charter on Human and Peoples’ Rights. ii. Violation of the Plaintiffs fundamental rights to fair trial and appeallate review under Article 7(1) of the African Charter on Huma and Peoples’ Rights. Iii. Violation of the Legal principles of separation of powers to the detriment of the Plaintiffs’ under Article 26 of the African Charter on Human and People’s Rights. iv. Imposition of mandatory death sentence in the Defendant’s statute books in violation of Articles 4 (g) and 5 of the Revised Treaty of ECOWAS, Article 1 of the African Charter on Human and People’s Rights, The International Covenant on Civil and Political Right and Other laws of Treaties respecting the rights to life and the right to freedom from torture, cruel, inhuman and degrading treatment. 4. FACTS AND PROCEDURE : 3

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