groups from criminal acts of third parties, the State ought to take measures within the scope of its powers to avoid that risk. 155. Specifically, the Applicants aver that the Respondent State has not taken sufficient initiatives to prevent killings and attacks on PWA, nor has it diligently investigated and prosecuted the perpetrators of such violence. The Applicants argue that since the year 2000, about 76 PWA have been reported attacked and killed and that several others have been mutilated or raped. 156. According to the Applicants, the killing of PWA has been the subject of several NGO reports, and concluding observations of many UN human rights bodies and other regional human rights bodies. In this regard, the Applicants submit that the Respondent State has violated Article 4 of the Charter, as well as Article 6 of the ICCPR. 157. By way of illustration, the Applicants aver that, on 12 May 2014, a 40-yearold woman with albinism was brutally murdered in Mwachilala sub-village in Simiyu Region. The killers severed her left leg from the knee, her left index and middle fingers and the upper part of her left thumb. 158. Moreover, the Applicants submit that on 21 October 2015, a 35-year-old man with albinism was attacked at his home in Mkuranga town, Dar es Salaam. He sustained serious injuries to the right side of his head and ear and never recovered from the injuries leading to his death on 24 April 2017. 159. The Applicants also submit that on 17 February 2015, the mutilated remains of a one-year-old boy with albinism were discovered by police in Shilabela Mapinduzi sub-village in Geita region with both of his arms and legs severed. * 160. The Respondent State contends that it has led the continental response to the attacks inflicted on PWA. It argues that since the murders were reported 38

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