8.
The Parties filed their pleadings on the merits and on reparations within the
time-limits set by the Court.
9.
IV.
Pleadings were closed on 14 March 2022 and the Parties were duly notified.
PRAYERS OF THE PARTIES
10. The Applicant prays the Court to:
i.
Note the violation by the State of Benin of human rights set out in the
Charter
due
to
the
Inter-ministerial
Order
No.
023/MJL/SGM/DACPG/SA/023SGG19 prohibiting the issuance of
official documents to wanted persons.
ii.
Order the State of Benin to bring the said inter-ministerial Order in line
with international human rights requirements.
11. The Respondent State prays the Court to:
i.
Find that the Applicant does not allege any situation of human rights
violation;
ii.
Find that the Applicant seeks to challenge an internal administrative act;
iii. Find that the Application falls outside the jurisdiction of the Court;
iv. Declare that it lacks jurisdiction.
v.
Note that administrative acts are subject to judicial review in Benin;
vi. Note that local remedies are available and effective;
vii. Find that the Applicant did not pursue any legal remedies;
viii. Find that local remedies were not exhausted;
ix. Declare the Application inadmissible;
x.
Find that the contested Order does not result in a conviction;
xi. Find that the said Order does not infringe the right to the presumption of
innocence;
xii. Declare that the said Order is not contrary to the Charter;
xiii. Note that nationality is a legal relationship of belonging to a state;
xiv. Note that Beninese nationality is governed by law;
xv. Note that the contested decree does not relate to nationality;
4