iii. Convicting the Applicant on insufficient evidence and the trial court, without justification, disregarding the fact that the trial assessors unanimously found the Applicant not guilty. iv. Not providing the Applicant effective counsel during trial. v. Imposing the death penalty despite failing to ensure that the Applicant was given a fair trial. b. A violation of the Applicant’s right to life under Article 4 of the Charter by reason of her mandatory death sentence, insofar as: i. The alleged offence fell outside of the narrow category of “most serious offences” to which the death penalty can lawfully be applied. ii. The Respondent State did not take the personal situation of the Applicant or the alleged offence into account in imposing the death sentence. c. A violation of the right to dignity under Article 5 of the Charter by: i. Sentencing mentally ill prisoner to death. ii. Sentencing the Applicant to death by hanging, which constitutes “cruel, inhuman or degrading punishment.” iii. Subjecting the Applicant to the psychological torture of “death row phenomenon”. d. A violation of Article 1 of the Charter by failing to give effect to the rights cited above. III. SUMMARY OF THE PROCEDURE BEFORE THE COURT 7. The Application was received at the Registry on 24 April 2019. 4

Select target paragraph3