SUMMARY OF FACTS The Plaintiffs are Nigerian Citizens and Community Citizens within the meaning of Article 1 (1) (a) of the Protocol suing for themselves and on behalf of the Members of Ette Community in Kogi State, Nigeria. The Defendant is a Member State of the Economic Community of West Africa States (ECOWAS) and a signatory to its Treaty, Protocols, Directives and Regulations as well as the Universal Declaration of Human Rights and the International Covenant on Civil and Political Rights. The Plaintiffs’ aver that Ette Community is a Community within the Federal Republic of Nigeria made up of Igala people who speak Igala language and by all existing boundary instruments including maps, gazettes gazetteers and ethnography, the Community has always been located in the North and now Kogi State. The location of the Community is represented in the colonial and post-colonial instruments and the existing maps showing the Northern Nigeria, the twelve (12) State structures, the nineteen (19) state structure (administrative and political) and the cultural map of Nigeria are all at the Defendant’s office of the Surveyor General. Ette Community shares a common boundary with Enugu state and as a result of the aggressive encroachment into its territory by the indigenes of Enugu state, the Kogi state Government initiated legal actions against Enugu 3