In response to the objection raised by the Defendant, the Applicants contends that the 1st Applicant is a legal person recognized and registered under Senegalese law. A proof of official registration was therefore attached and marked "Annex 1". The Applicants further pointed out that this Court has already granted standing to the 1 st Applicant in a previous proceeding; the 1st Applicant under its alternative name ' International Federation of Journalists Africa'- was the 3rd Applicant in the recent case of Hydara V. The Gambia, ECW/CCJ/APP/30/11. The Applicants further contends that the Respondent's second point is irrelevant and does not advance its case as there is no restriction in this court's rule on locus standi for human rights cases which requires that, in the case of membership organizations, only entities with membership exclusively from ECOWAS member states are entitled to bring applications before the court. The Applicants submits that, insofar as the nationality of a non-governmental organization is relevant, it must be that the location of the country in which it is registered, and whether it is properly recognized that matters. The applicants submits that the 3rd applicant continues living in exile even till date, to suffer a violation of her rights as a journalist, her rights of freedom of expression and liberty by virtue of her being forced to remain in exile. In addition, they continued that the Gambia's persistent and continuous omission in failing to repeal the domestic criminal laws under which the 3rd Applicant's rights 12