crude gas explorations have done and are still doing to the Niger Delta. The Plaintiffs further state that the Defendant has failed or neglected to reduce the frequent incidences of crude oil spills and gas flaring that have killed or incurred health hazards to thousands of people in the Niger Delta. That the above acts complained of constitute a violation of their fundamental human, civil, social and economic right of ownership, use and benefit of the natural resources in their ancestral land. The Defendant has overlooked the apparent inhuman suffering and recurrent deaths occasioned by ill-health caused by severe damage to the environment in the oil producing communities. That unless the Defendant is restrained from renewing the already expired oil mining blocs exploration licenses, the people of the Niger Delta shall continue to suffer from these crude oil exploration activities. Whereupon the Plaintiffs filed this application seeking for the following orders: i) A DECLARATION: that the unilateral allocation of Crude Oil Blocs to private Nigerians and their firms by the Federal Government of Nigeria in total disregard to the people of the communities in whose lands the crude oil is located is unlawful and same violates their Fundament Rights as entrenched in Article 21, 22 & 24 of the African Charter on Human and Peoples Rights (ACHPR); Article 1 (1-3) of the International Covenant on Civil and Political Rights (ICCPR); and Article 1 (1-3) & 11 of the International Covenant on Economic, Social and Cultural Rights (ICESCR). 6

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