19. After serving a twenty – four (24) month –
imprisonment, with 10 months as suspended
sentence, he was sacked, for serious misdemeanor,
by his employer, the company known as TogoTelecom.
20. He further claimed that he is now suffering from
high blood pressure, eye pains and anal fistula,
sequel to the actions of the Togolese security
agents, and tendered a medical report dated 2
September 2016, which was issued by Pr. DOSSEH
Ekoué David, a Surgeon at the C.H.U Sylvanus
Olympio in Lomé, as exhibit, to back – up his claim;
21. He finally claimed that he was victim of torture,
arbitrary detention, and that his right to work was
violated, and invoked, among other things, the
Constitution of Togo, the African Charter on
Human and Peoples’ Rights, the Universal
Declaration of Human Rights, the UN Convention
against torture, the International Covenant on Civil
and Political Rights, and the International
Covenant on Economic, Social and Cultural Rights.
22. In its Exceptional Memorial in defence, the
Republic of Togo pleaded with the Court to set aside
the case filed by Plaintiff/Applicant for lack of
quality to act by the Collectif des Associations
contre l’Impunité au Togo (CACIT) which
represented Mr. AGBETOGNON Koffi;
23. Indeed, the Defendant State held that the
Collectif des Associations contre l’Impunité au
Togo failed to produce any mandate given to it,
7