iv. Section 39 of the 1999 Constitution of the Federal Republic of Nigeria as amended. c. 27. i. Reliefs Sought The Applicants seek the following reliefs from the Court: A DECLARATION that the Applicants, and indeed the citizens of the Federal Republic of Nigeria are entitled to protection and guarantee of the fundamental freedoms enshrined and guaranteed under the Articles of the Universal Declaration of Human Rights, African Charter on Human and Peoples’ Rights, and International Covenant on Civil and Political Rights pertaining to their rights to freedom of speech and expression. ii. A DECLARATION that the Respondent is bound to observe and respect the Applicants’ rights to freedom of speech and expression as enshrined and guaranteed under the Universal Declaration of Human Rights, African Charter on Human and Peoples’ Rights, and the International Covenant on Civil and Political Rights, and under its Constitution. iii. A DECLARATION that the initiatives by the Respondent to legislate into law, the ‘Hate Speeches’ Bill which by its purport criminalizes speech, is contrary to Article 9 of the African Charter, Article 19 of the Universal Declaration of Human Rights and Covenant on Civil and Political Rights, and a violation of the Applicants’ fundamental rights. iv. A DECLARATION, that the Hate Speech Bill, which is evolving into a substantive law by the Respondent is not within the permitted restrictions under Article 27(2) of the African Charter, not being proportionate to the aim of the international instrument, and is an infringement on the Applicants’ rights to freedom of speech and expression. 8

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