ii. The Respondent state, through enactment of section 148(5) has violated Art 2, 9(1), (3), (4), 14(1), (2), 3(c) and 26 of ICCPR, and, 1, 2, 3, 6, 7, 9, 10 and 11(1) of UDHR. iii. That the Respondent State puts in place Constitutional and Legislative measures to guarantee the rights provided for under Article 1, 2, 6 and 7 of the Charter and other international human rights instruments. iv. Make an order that all suspects and accused persons charged with unbailable offences, be released on bail within one month from the date of the decision under the bail conditions set by the Respondents Courts, based on circumstances of each case. v. Make an order that the Respondent reports to the Honourable Court, within a period of twelve (12) months from the date of judgment issued by the Honourable Court, on the implementation of this judgment and consequential orders. vi. Any other remedy and/or relief that the Honourable Court will deem to grant; and vii. The Respondent to pay the Applicant’s costs. 12. With respect to jurisdiction and admissibility, the Respondent State prays the Court to find that: i. The Applicants’ Application has not met the admissibility conditions under Article 56(2), (5), (6) and (7) of the Charter; ii. The Application be declared inadmissible for contravening Rule 41(3)(e) of the Rules of Court; and iii. The Application be declared inadmissible for contravening Article 56(7) of the Charter and Article 6(2) of the Protocol. 13. With respect to the merits of the Application, the Respondent State prays the Court to find that: 1. The Section 148(5) of CPA does not violate the provisions of Articles 1, 2, 6 and 7 of the Charter; Articles 1, 2, 3, 6, 7, 9, 10 and 11(1) of the UDHR; Article 2, 9(1), 9(3), 9(4), 14(1), 14(2), 14(3)(c) and 26 of the ICCPR and Article 13(1), 13(2), 13(3), 13(4), 13 (6)(a) and (b), 15(1), 15(2) and (b) of the Constitution; 5

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