Terrorist Group but may have interacted with them “unknowingly” while living as tenants in the uncompleted building. The Applicants shall relied on page 62 of the Senate Report. It is the reasonable expectation of the Applicants that law enforcement agents, including members of the 2nd and 3rd Defendants, are required to be circumspect in the exercise of their duty and to also provide compensation to any innocent victim who loses his property, limb or life in the course of operation leading to the violation of the Applicants’ rights. That during the Question and Comments session with the Commander, Guards Brigade, of the 2nd Defendant, he conceded that compensation to the victims could heal wounds. Below is a representation of the interaction as contained in page 56 of the Senate Report; At the Senate Joint Committee hearing, the Counsel to the Applicants, Mr. Sanusi Musa, who presented a written submission did request the Senate Joint Committee to direct the payment of compensation to the victims as follows; a. N 100,000,000 to each of the victims as follows; b. N 20,000,000 to each of the injured. However, this request was never heeded. The failure to heed to this request is because the Nigerian Government has deliberately and actively insisted on ZERO COMPENSATION to innocent victims of the 1st Defendant fight against Boko Haram insurgency. Prior to the episode of 20th September 2013, the Nigerian Government set up a Presidential Committee on the Security challenges in the North-East relating to acts of insurgency and terrorism. The Presidential Committee in the month of November 2013 submitted its report to the President of Nigeria recommending that Nigeria should pay compensation to the victims of the Boko Haram insurgency. However, by several newspaper publications circulated within Nigeria on the 6th day of November 2013, the Nigerian Government rejected the recommendation. The Socio –Economic Rights and Accountability Project, SERAP, (a renowned non-governmental organization reputed for fighting for the enthronement of the rule of law and the enforcement of fundamental rights in Nigeria) petitioned the 5

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