'revenue from onshore resource extraction will flow to Luanda just as offshore revenue does now'. The Complainant argues that a 2006 Cabinda Peace Accord which promised a 50% return of oil revenue to Cabinda 'has not been realised or audited' and only '10% or less will return to Cabinda'. The Complainant alleges further that any attempt to question the allocation of revenue has resulted in summary imprisonment 'as in the case of Global Witness Investigatory' staff who was arrested and charged by Angolan Police after meeting with local representatives of civil society in Cabinda. 61. The Complainant alleges further that in spite of the abundant oil resources in Cabinda unemployment is high and poverty, infant mortality and disease are higher in Cabinda than in most areas of Angola. The Complainant adds that Cabinda's resources have 'subsidised the government of Angola' and the 'Angolan administration has little concern for providing public goods and incentives to facilitate investment in welfare enhancing improvements for the population at large'. Thus, the Complainant alleges that the Respondent State has violated Article 19 of the African Charter. 62. Regarding the alleged violation of Article 20 of the Charter, the Complainant emphasises that the people of Cabinda are geographically, politically, linguistically and culturally distinct from Angolans so that they are have a right to social and economic development. The Complainant contends that the people of Cabinda are unable to exercise this right because organisations which 'espouse a uniquely Cabindan point of view' have been banned by the government of Angola. Complainant alleges further that Cabindans who campaign for economic self-determination are routinely arrested as 'FLEC sympathisers' while foreigners who have identified corruption in Cabinda have been sent to jail. Accordingly the Complainant claims that the Respondent State has violated Article 20 of the African Charter. 63. On Article 21 of the African Charter, the Complainant contends that grants and concessions (what it terms onshore oil and mineral rights offerings) have been made by the Respondent State 'without input from the Cabindans' and that all decisions regarding natural resources are made from Luanda, the Capital of Angola. The Complainant contends that the Cabinda people and FLEC as the representative of the Cabinda people have not been adequately consulted about the management of 'their onshore resources. Rather, exploration and exploitation activities have been undertaken under the watch of the Angolan Armed Forces. Thus, the Complainant disputes the legal right of the Respondent State to exploit and dispose onshore resources in Cabinda and alleges that such activities amount to spoliation which is in violation of Article 21 of the African Charter and therefore should be redressed by the Respondent State. 64. On the alleged violation of Article 22 of the African Charter, the Complainant asserts that the people of Cabinda are a distinct people with a right to economic and social development and contends that the current policy of the Respondent State is one of 'Angolanisation of Cabinda' involving discriminating against and arresting individuals and groups that claim a Cabindan identity. Accordingly, the Complainant alleges that the Respondent State has violated Article 22 of the African Charter. 65. Regarding Article 24 of the African Charter, the Complainant alleges that the environment in Cabinda is not conducive for the development of the people of Cabinda. While it claims it does not seek an ideal environment, the Complainant argues that it seeks an environment that permits 'some measure of equity for the people of Cabinda'. The Complainant contends that the operations of companies such as Chevron take place in conditions that harm human health and the environment because the Respondent State has failed to enforce compliance with environmental rules. 66. The Complainant alleges further that the absence of viable civil society in Cabinda following the ban on the Mpalabanda organisation ensures that the activities of oil companies are not monitored and no compensation is paid in the event of damage to the environment. The Complainant therefore argues that the Respondent State has violated the right of the people of Cabinda to a satisfactory environment as guaranteed in Article 24 of the African Charter. 67. In support of all its allegations, the Complaint has submitted five documents as exhibits. They include a "Republic of Kabinda January 8 2010 Committee Report on the Togolese Incident"; a 1974 joint communiqué between Popular Movement for the Liberation of Angola MPLA) and the Complainant (FLEC); a Human Rights Watch report titled "They Put me in the Hole - Military Detention, Torture and Lack of Due Process in Cabinda"; a 2008 Chevron Alternative Annual Report titled "Chevron in Angola" and an Amnesty International Public Statement titled "Angola: Human rights organization banned". Also submitted in support of the Complainant's case are historical accounts presented by different bodies acting on behalf of the peoples of Cabinda. 6