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

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