5.1.1. Applicants are victims of Explosive Remnants of War, Landmines and Bombs. The Applicants are those whose Fundamental Human Rights are violated and threatened. 5.1.2. There are more bombs scattered in the Applicants Community/Environment in Imo State. The Applicants are a class of persons whose Fundamental Human Rights have been violated, and threatened by bombs and landmines in the kitty of the Respondents; and they did not fight the Nigerian Civil War, but were severely injured by landmines explosions, other Explosive Remnants of the War abandoned in their Autonomous Communities/ Environment by army after the Nigerian Civil War such having not been cleared by the Federal Government of Nigeria. 5.1.3. The Applicants are persons/victims injured after the Nigerian Civil War by landmines or other Explosives Remnants of Nigeria Civil War, who are still living in contaminated communities in Isiala Mbano, LGA, Imo State. Applicants have common interests and will enjoy common benefits by the outcome of this suit. They were affected by non-education and non-clearance of landmines and bombs after the Civil War. 5.1.4. The Applicants state that they have not been going to their farms since their accidents. The continuing threats and presence violate their right to life, right to satisfactory healthy environment and right to freedom of movement, as well as limited their abilities to attain adequate, effective and effectual physical and mental health and development as they are almost perpetually traumatized and disabled. 5.1.5. The Applicants state that the Federal Government represented by the Ministry of Defense, 3rd Respondent, hired the services of the 4th Respondent, R. S. B. Holdings Nig. Limited. They started work between 2009 and 2011 and midway in 2011, the contractors were stopped from clearing and since then they have not returned to work in spite of all pleas by Applicants. 5.1.6. The Applicants state that the 2nd, 3rd, and 5th Respondents have not allowed the 4th Respondent, R. S. B. Holdings Nig. Limited access to facilities to destroy the bombs, but have allowed the Applicants, their communities and environment to continue to live with live bombs. -5– 5.1.7. Applicants aver that their contaminated Lands/Environment/farmlands should be treated for agricultural purposes and sustainable developments.

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