d. An Order mandating and compelling Togo to take all necessary
measures to guarantee measures of non-recurrence in order to prevent
the same violations occurring again in future;
e. An Order mandating and compelling Togo to effectively enact and
implement laws, regulations and safeguards in order to meet its
obligations with respect to the right to freedom of expression under
international human rights law, including under the African Charter,
ICCPR and the Revised ECOWAS Treaty;
f. An Order mandating and compelling Togo to issue adequate
reparations, including restitution, compensation and measure of
satisfaction to the Applicants, to be specified and submitted to this
Honorable Court in due course; and
g. Such further order/s remedy and/or relief as this Honorable Court may
deem fit to grant in the circumstances.
D. The Respondent’s Defense
12. The Respondent states that there were protests since the 17th August 2017 and
that the same were orchestrated by the opposition party, Le Parti National
Panafracin (PNP) in conjunction with other political groups.
13. The Respondent also avers that even though freedom of association and peaceful
demonstration is guaranteed by the constitution of Togo of 14 th October 1992 the
same is conditioned by law. That Law no. 2011-010 of 16 May 2011 was a means
of giving effect to the constitutional provision which enables administrative
authorities to regulate all public manifestations, and that the Respondent had
submitted that it be adopted. That having made some observations of the itinerary
proposed by the organizers an alternative itinerary was proposed by the
authorities.
14. The Respondent avers that the PNP disregarded the proposal of the authorities
and proceeded to carry on with its original proposal which resulted in skirmishes.
That the opposition party formed a coalition with other political parties and
demanded for a return to the Togolese Constitution of 27th September, 1992 which
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