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.
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5.1.7. Applicants aver that their contaminated Lands/Environment/farmlands
should be treated for agricultural purposes and sustainable developments.