i.
That the failure on the part of the Defendant State to recognize, promote
and protect the rights of the Plaintiffs and the failure to take measures to
give effect to the rights of the Plaintiffs constitute multiple violations of
Articles 1, 2,3,5 and 18 (3) of African Charter on Human and Peoples’
Rights, Articles 2,3,4(1) and (2), 5, 8 and 25 of the Protocol to the African
Charter on Human and Peoples’ Rights on the Rights of Women in
African, Articles 2,3,5 (a), and 15 (1) of the Convention on the Elimination
of All Forms of Discrimination Against Women, Articles 2(1) and (3), 3,
7 and 26 of the International Covenant on Civil and Political Rights,
Articles 10, 11, 12, 13 and 16(1) Covenant Against Torture and other
Cruel, Inhuman or Degrading Treatment or Punishment and Articles
1,2,5,7 and 8 of the Universal Declaration of Human Rights.
ii.
That the failure and /or refusal of the Defendant State to investigate,
discipline and prosecute the persons responsible for the violations of the
Plaintiffs’ Rights, amounts to a violation of the States International
obligations.
iii.
That the treatment meted out to the Plaintiffs by agents of the AEPB, the
Nigerian Police and the Nigeria Military constitute gender- based
discriminatory treatment contrary to articles 2, 3 and 18(3) of the African
Charter on Human and Peoples’ Rights, Articles 2 and 8 of the Protocol to
the African Charter on Human and Peoples’ Rights on the Rights of
Women in Africa of Articles 2,3 and 15(1) of the |Convention on the
Elimination of All Forms of Discrimination Against women, Articles 2(1),
41