IV.
PRAYERS OF THE PARTIES
21. The Applicants request the Court to find that the Respondent State violated
the rights referred to in paragraph 16 above and to order it to:
i.
Publicly acknowledge its responsibility for the violations referred to in the
Application and publicly apologise, in particular to the victims of the toxic
waste dumping and the consequences thereof;
ii.
Open an independent and impartial investigation in order to establish
liability for the waste and prosecute persons involved for their criminal
liability, regardless of their status or employment within TRAFIGURA or
the office they hold in the country;
iii. Ensure the provision of medical assistance to victims, including
treatment of new symptoms, and in the long-term, illnesses caused by
exposure to toxic waste, establish adequate health facilities and provide
qualified personnel and appropriate equipment to provide the necessary
care so as to improve the health of the victims of toxic waste;
iv. Immediately roll out an adequate and effective compensation
programme for victims of toxic waste, beginning with a national census
of victims of waste dumping, taking into account the continuous
presence of toxic waste for nearly a decade, and ensure that the result
of this census is disseminated to the public, and to consult with the
victims after the programme has been put in place, in order to determine
a quantum of compensation that is commensurate with their
expectations and needs;
v.
Immediately take measures to prepare a comprehensive national study
on the health and environmental effects of dumping the toxic waste in
the short, medium and long term, ensure that the study is widely
disseminated and inform the public of measures taken to address the
short, medium and long-term negative effects of toxic waste on human
health and the environment;
vi. Submit a transparent and publicly accessible report on the use of the
lump sum allocated to Côte d’Ivoire under the Memorandum of
Understanding signed with TRAFIGURA; and;
vii. Implement structural reforms to enhance waste handling capacity in the
port of Abidjan by adopting environmentally friendly methods,
8