4. That on or about the 2nd day of January 2016, the Benue State Police Commissioner, Paul Yakadi, revealed that over 5,000 cows accompanied by armed Fulani herdsmen were occupying parts of Agatu Local Government Area(LGA) of the State. Some of the Applicants’ leaders have brought the facts of these predictable attacks and locations of these Fulani militia to the attention of the Respondents at various times but the Respondents failed and /or neglected to take proactive measures to protect them. 5. That the 2nd Respondent is a grand patron of the Fulani herdsmen in Nigeria and is known to have fought for and sought protection of these Fulani herdsmen in the past. The Fulani herdsmen then took advantage of his position as President to wreak havoc on the people of Benue state without being apprehended. A case in point was on 4th day of march 2016, when one Ardo Boderi claiming to be a leader of the Fulani herdsmen said at a stakeholders meeting organized by the 3rd and 4th Respondents, claimed that because over 10,000 cattle belonging to the Fulani marauders were allegedly killed by people of Agatu, that was why he and his members attacked and killed people of the Agatu community. Despite this admission, the 4th Respondent never ordered the arrest of the said leader. 6. That after the killings of over 500 people and 10 villages razed down in Agatu LGA, the 2nd Respondent through his Minister of Interior, purportedly setup an investigation panel to enquire into the atrocities committed by these militias, but till date, the said report of the investigation panel has not been published nor any findings or recommendations reported. That the Respondents chose to protect cows belonging to these herdsmen as against lives of its citizens by deploying heavily armed military and mobile policemen to the bushes to protect the said cows. 7. That since the unfortunate Fulani attacks, the Applicants communities and thousands of their kinsmen have been camped in primary schools and shanties under deplorable conditions unworthy of human lives and bereft of basic necessities such as food and medical care. These callous attacks have been reported in various media and these incidents are common knowledge in Nigeria but, in spite of this, the Respondents have refused and or willfully neglected to provide any relief materials to ameliorate their sufferings. 4

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