14. The Applicants aver that the Order is still in force and all requests for
demonstrations and peaceful protests in the said areas have been denied.
They claim this is in violation of the rights to freedom of assembly, freedom
of expression and freedom of movement of the Applicants and Senegalese
people guaranteed in Articles 11, 9(2) and 12 (1) of the African Charter on
Human and Peoples’ Rights (African Charter) respectively, and other
relevant provisions of international human rights treaties.
15. The Applicants therefore filed this Application before the Court for relief
for the violation of their rights and of those Senegalese citizens by the
Respondent in this regards.
a) Pleas in law
16. The Applicants rely on the following laws:
i. Order No 007580/MINT/SP of 20 July 2011;
ii. Articles 9(4) and 10(d) of the Supplementary Protocol of 2005;
iii. Articles 8 and 10 of the Constitution of the Republic of Senegal;
iv. Articles 9, 11 and 12 of the African Charter;
v. Articles 12, 18(3), 19 and 21 of the International Covenant on Civil and
Political Rights (ICCPR);
vi. Articles 13, 19 and 20(1) of the Universal Declaration of Human Rights
(UDHR).
b) Reliefs sought
17.
The Applicants pray the Court to grant the following reliefs:
i.
Find the violation by the Republic of Senegal of the freedom of
assembly and demonstration guaranteed by the provisions of Articles 8
6