vii. Order the annulment of Law No. 2019-39 granting amnesty for criminal
acts, misdemeanours, or minor offences in connection with the 2019
legislative elections insofar as the said amnesty absolves the
perpetrators of human rights violations of any responsibility and violates
the right of victims to an effective remedy;
viii. Order the Respondent State to set up an independent commission of
inquiry to investigate the killings that took place between April and June
2019 in Kilibo, Banté, Cadjéhoun (Cotonou), Savé, Tcharou and Kandi,
and to bring to justice the masterminds, perpetrators and accomplices
of those atrocities, identify the victims of the pre- and post-electoral
violence and pay them fair and adequate compensation;
ix. Order the Respondent State to pay the Applicant One Hundred Million
(100,000,000) CFA francs in damages for moral prejudice;
x.
Report to the Court, within such time as the Court may direct, on the
steps taken to expeditiously execute the judgment on the merits;
xi. Order the Respondent State to pay costs.
12. The Respondent State prays the Court to:
i.
Find that the Applicant does not allege any concrete situation of human
rights violation;
ii.
Consequently, declare that this Court lacks jurisdiction;
iii.
Declare that the Court has already found that there is no link between
the additional application and the initial application;
iv.
Note that the anonymous Applicant is, as of this date, the author of
about ten applications on the merits and requests for provisional
measures requested as a matter of urgency since 2019 concerning
various situations that he claims to be the cause of human rights
violations and for various beneficiaries that he cannot identify
personally;
v.
Find that the same person cannot, at the same time, have a real,
natural, present and legitimate interest in causes that are so disparate
both materially and temporally;
vi.
Find that the anonymous Applicant’s multiple applications approach
constitutes abuse of court process;
5