d. Order the Respondent State to compensate him to the tune of Tsh 65,800,000/= which he would have earned out of his agricultural produce; and e. Order the Respondent State to compensate him for special damages in an amount that the Court deems fair in the circumstances. 12. In its response on jurisdiction and admissibility, the Respondent State prays the Court to: a. Declare that it is not vested with jurisdiction to adjudicate this Application; b. Declare that the Application has not met the admissibility requirements under Rule 40(5) and (6) of the Rules of the Court; c. Declare that the Application is inadmissible; and d. Dismiss the Application. 13. On the merits, the Respondent State prays the Court to: a. Declare that the Government of the United Republic of Tanzania did not violate the Applicant’s rights provided by Article 2 of the African Charter on Human and Peoples’ rights; b. Declare that Tanzania did not violate the Applicant’s rights under Article 3(1)(2) of the African Charter on Human and Peoples’ rights; c. Declare that Tanzania did not violate the Applicant’s rights under Article 7(1) of the African Charter on Human and Peoples’ rights; d. Declare that Tanzania did not violate the Applicant’s rights under Article 7(1)(c) of the African Charter on Human and Peoples’ rights; e. Declare that Tanzania did not violate the Applicant’s rights under Article 7(1)(d) of the African Charter on Human and Peoples’ rights; f. Declare that Tanzania did not violate the Applicant’s rights under Article 107A (2)(b) of the Constitution of the United Republic of Tanzania, 1977; g. Dismiss the Application in its entirety for lack of merit; h. Dismiss the Applicant’s prayers in entirety; i. Dismiss the Applicant’s prayer for reparations; and j. Order the Applicant to pay the costs of this Application. 5