- ORDER the said member states to review both the Treaty and CIMA Insurance Code to
ensure protection of human rights.
ORDER
also
the
annulment
of
26
October
2012
Decision
No.
00020/D/CIMA/CRCA/PDT/2012 OF THE REGIONAL INSURANCE CONTROL
COMMISSION (CRCA) taken against the Company based on the unlawful provisions cited
above, and by which the withdrawal of its licence was pronounced (Exhibit # 1) and
consequently, ORDER Member States of CIMA to repair the damage suffered, particularly by
the partners and the Company itself.
This prayer for annulment is made on the following grounds:
- Violation of Articles 8 and 10 of the Universal Declaration of Human Rights;
- Violation of the Preamble and Article 4 of the International Covenant on Economic, Social
and Cultural Rights;
- Violation of the Preamble and Articles 2 (3) and 14 of the International Covenant on Civil and
Political Rights;
- Violation of Articles 1, 3 and 7 of the African Charter on Human and Peoples’ Rights;
- Abuse of power by CIMA organs;
- Abuse of authority by CIMA organs;
- Erroneous assessment of the personal status of the Company and its representatives.
D. MEASURES REQUESTED
The Applicant requests as follows:
1. On the material damage, order the Commission to pay reparation in the sum of 1,300
000,000 CFA F at the least.
2. On the professional damage, reparation for “all of its losses which cannot be less than 3
billion CFA Francs."
3. The damage to the image of the company, order the Commission to pay reparation in
the amount of 3 billion CFA F.
4. On the professional prejudice, order the CIMA to pay reparation in the amount of 6 billion
CFA F
5. On the financial damage of SANTEPHONE project, order the CIMA to pay reparation in
the amount estimated at 87,898,125,000 CFA F.
6. On the financial prejudice resulting from other projects, order CIMA to pay the sum of
six billion CFA F and order CIMA to serve the Company with that sum.