12. That he was thus detained by virtue of an arrest warrant issued on 25 September 2014 whose validity and enforceability cannot be sustained before the decision made by the judges of the court of first instance on 30 January 2015, who ruled that the procedure initiated had no legal basis unless there was a prior decision by a civil court on the issue of parentage and blood relationship. 13.That contending that his human rights were violated, he brought the matter before the Community Court of Justice, ECOWAS for violation of his right to security, his right to equality before the law, his right regarding violation of the law of nulla poena sine lege, his right to fair hearing, and his right to family life. 14.That in response, the Republic of Niger argued, through the written pleadings of his Counsel Maître Moussa Coulibaly, that in 2014, the Nigerian media reported on the discovery of a huge inter-State child trafficking syndicate in the sub-region. That under aegis of a police cooperation framework among ECOWAS Member States, a dispatch was sent from within the Niger Police Force to Nigeria to investigate, and in their report, they made mention of the dismantling of a child trafficking network named ‘baby factories’. That searches conducted on the premises of those ‘baby factories’ led to the discovery of young ladies who were held in captivity till they give birth, and their babies were sold by one Agoundeji Happiness, at 800,000 Naira for a boy and between 300,000 to 400,000 Naira per girl. 15.That the preliminary inquiry of the Criminal Investigation Division (CID) of the Niger Police led to the arrest of 18 persons for questioning including Madam Adizatou Amadou Dieye, the wife of the Applicant. 16.That Madam Adizatou Amadou Dieye challenged the charges made against her and stated that she gave birth to a set of twins on 1 September 2012 without indicating the health centre where she gave birth. That questioned on the birth certificates of the children concerned, she asked the investigators to find out from Hama Amadou, her husband, disclosing further that the children are holders of diplomatic passports of Niger. Translator : E. Nkansah 6

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