1- That they were not aware of Title Deed No. 18, which substantiates
the ownership of the State of Niger over the disputed land;
2- That the Court's Decision did not take into account the destruction of
personal property and the deprivation of their occupation right;
3- That the contested decision with regard to discrimination ignores the
content of the citizen Mainassara parcel title, which demonstrates,
without ambiguity, according to them, that his plot is within the limits
of the same title deed;
79. In the instant case, all parties agree that the litigation was initiated before
the national courts. They exchanged documents following the sacrosanct
principle of an adversarial process, and the Applicants cannot now usefully
claim that they were unaware of the Niger State Title Deed.
80. However, for the legal text relied on above to be applied, the Applicants
would have to demonstrate that they were aware of new elements that they
did not have the opportunity to discuss before the courts.
81. The doctrine and jurisprudence unanimously admit that the application
for Revision tends to portray the final decision so that it can be re-judged in
matters of fact and law;
82. It is common knowledge that the application for Revision is, inter alia,
open if, for example:
16