the highest rates per country in the world, at 1 in 1429 people. It is submitted that throughout history, PWA in the Respondent State’s territory have endured persecution and humiliation, resulting in mutilations and killings. 7. The Applicants aver that the substratum of the attacks on PWA is particularly located in tribal beliefs and practices, some of which characterize children born with albinism as a curse. Therefore, killing of the children was perceived as an act of cleansing the community of the curse. Other beliefs related to PWA are that:6 They are ghosts, thus they never die; having sexual intercourse with a woman with albinism can cure AIDS; body parts of PWA can be magically used to generate wealth, and, when a child is born with albinism, it is the mother’s fault. 8. Furthermore, the Applicants assert that as a general practice, the assailants of PWA target their body parts when they are alive, desecrate the graves of those who are deceased, dismember their bodies and steal the parts, mainly for witchcraft purposes. The Applicants submit that, robbery of body parts in the Respondent State’s territory have been reported along with outright human trafficking of PWA. 9. The Applicants aver that from the year 2000 to June 2016, the total number of deaths in the Respondent State’s territory was 76, whilst the number of survivors of attacks and kidnappings were 69. According to the Applicants, as PWA are a minority population, such high numbers are indicative of a serious and widespread threat to their existence. 10. It is also the Applicants’ assertion that most PWA have meagre job prospects. This situation forces them to take up menial jobs which further expose them to ultraviolet radiation from the sun, making them susceptible to skin cancer. The Applicants aver that with these conditions, most PWA in the Respondent State’s territory have difficulties accessing essential social services. 6 Under the Same Sun ‘Children with Albinism in Africa: Murder, Mutilation and Violence’ (2012) 15. 4

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