8. The Applicants therefore seeks the following reliefs: 1. A DECLARATION that the failure of the Respondents, their officers, servants, agents and privies to provide a security for the Applicants and their properties but rather deploy security operatives to protect cows owned by nomads roaming the bush constitute a gross violation of Applicants’ right to be equal before the law and violates their entitlement to equal protection of the Law contrary to Article 3 of the African Charter on Human and Peoples Rights. 2. A DECLARATION that the failure of the Respondents, their officers, servants agents and privies to provide adequate and timely security to the Applicants is a gross violation to the Applicants’ right to liberty and security of their persons contrary Articles 4 and 6 of the African Charter on Human & Peoples’ Rights. 3. A DECLARATION that the Applicants have a right to National and International Peace and Security as enshrined in Article 23 of the African Charter on Human & Peoples’ Rights, and the failure of the Respondent, their officers, servants, agents and privies to take proactive measures to provide timely and adequate protection for the Applicants and their communities from the occupation of their farm land and utter destruction of their properties Fulani Herdsmen constitute gross violation of the said rights. 4. A DECLARATION that the current degradation of the environment in the Plaintiffs’ ancestral homes and communities due to destruction of same by Fulani Herdsmen occasioned by failure of the Respondent, their officers, servants, agents and privies to provide adequate and timely security to them is a gross violation of their right to a general satisfactory environment favorable to their development contrary to Article 24 of the ACHPR. 5. A DECLARATION that the failure of the Respondents to secure the borders of the country constitutes a flagrant violation of the Plaintiffs’ right to national and International Peace and Security as enshrined in Article 23 of the ACPHR. 6. A DECLARATION that the deplorable state of health that pervades the Internally displaced Persons (IDP) Camps littered across Benue State constitute gross violation of the Plaintiffs’ and their kinsmen’s right to enjoy the best attainable state of physical and mental health as guaranteed by Article 24 of the ACHPR. 5

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