the Discrimination against Persons with Disabilities (Prohibition) Act, 2018 to address the alleged violations. Particularly, according to the Respondent State, the Criminal Code of Akwa Ibom clearly criminalizes accusation of children of witchcrafts. 38. The Respondent State submits that it has implemented policies for free universal basic education, free medical services, shelters, and skills acquisition centers for vulnerable children. These measures demonstrate a holistic commitment of the Respondent State to the physical, mental, and social development of all children, fulfilling its obligations. It further states that it has prosecuted three cases relating to witchcraft accusations, including one involving a child (The State v Eteyen Edet Ifang with charge number HEK/35C/2015). The Respondent State asserts that these actions demonstrate due diligence and contributed to a significant drop in such cases. 39. The Respondent State submits that it provides for free compulsory education for all children and highlights stories of children accused of witchcraft that have successfully completed their education through government support. By alluding to these facts, the Respondent State submits that it has complied with its obligation under the Charter to protect the rights of children accused of witchcraft accusation. Observation of the Complainants on the Submission of the Respondent State 40. The Complainants allege that the Respondent State's submissions in its Argument on the Merits are insufficient and fail to address the continuous and widespread nature of violations against children accused of witchcraft. They contend that the Respondent’s focus is limited to past measures in Akwa Ibom State, while the problem persists across numerous states in Nigeria. As evidence, the Complainants provide recent documented cases to demonstrate the continuing nature of the violations, they have also attached the evidence as annex to their submission. The Complainants further challenge the efficacy of measures reported by the Respondent State such as the establishment of the family courts, and translation of laws, arguing that such measures are generic and not tailored to address the specific harms associated with witchcraft accusations. Moreover, the Complainants submit that the Respondent State has not demonstrated how its generic policies on survival, development, and education protect children from the specific threats posed against them by witchcraft accusations. They argue that the sensitization campaigns cited by the Respondent State are without proof and ineffective considering the persistent nature of the violations. 41. The Complainants argue that the Respondent State has not fulfilled its positive obligations under the Charter. They cite established jurisprudence indicating that a State's duty extends beyond enacting laws to actively ensuring effective implementation through enforcement and prosecution. The Complainants also argue that legal provision cited by the Respondent State on the criminalization of the practice under Section 160 of the Akwa Ibom Criminal Code, is inadequate as it is not child-specific, does not cover violations like murder, and is geographically limited to Akwa Ibom State. Furthermore, the Complainants argue that the prosecuted cases mentioned in the Respondent’s arguments are few, outdated, 11

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