10. Whereas in support of their claims, Plaintiffs/Applicants aver, through their above named Counsels that the termination of their appointments in 2006 was sequel to the bankruptcy and liquidation of their former employer, a state owned company known as Sierra National Airlines; 11. They claim that, at the time of the liquidation of the said state owned company, they incurred great losses in the sense that they lost their means of livelihood, without being compensated substantially, in a way as to make – up for their losses. This situation, according to them, constitutes an infringement upon their socieconomic rights, such as the right to earn compensation (in terms of salary, salary arrears, severance pay, the right to own property…), which are guaranteed under international legal instruments stated above, especially, Article 21 of the Sierra – Leonean Constitution and Article 14 of the African Charter on human and Peoples’ Rights. 12. Plaintiffs/Applicants equally claim that Article 27 (a) and (b) of the Statutes of the Defendant company – Sierra National Airlines - provides that: ‘‘Payment of emoluments shall not be unduly delayed, for whatsoever reasons. When the waiting period becomes so long that it has affected years of service, which shall be calculated in arrears, the Employer must base the calculations of emoluments, to cover the whole waiting period.’’, thus, they aver that they are right under the law, to claim, without further delay, all their rights inherent in the loss of their jobs. 13. On this note, Plaintiffs/Applicants conclude by averring that << the significance of this Article is that the severance allowances of all the former workers should be recalculated, and that the salary arrears due and owed them must be revised, by adding at least, an amount of Le 1,000,000,000 (one billion Leones) to each year passed during which there was no payment of severance pay to Plaintiffs/Applicants by Defendants. >> 6

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