4 the application and set down their grounds which their cow1sel argued. Arguing the grounds for the preliminary objection, the defence counsel stated that the plaintiff had failed to exhaust local remedies and as such this Court should not entertain this suit. Defendant contended that plaintiff has counsel who litigated this matter on its behalf in the Senegalese Court but did not exhaust all the avenues open to it before bringing the same matter to this Court. Defendant concluded this leg of her arguments by positing that in international courts like tl1is one, local remedies, judicial or not, ought to be exhausted before the court could assume jurisdiction and cited the European Court of Human Rights as an example. 8. The defendant also argued that the plaintiff was incompetent to come under the provisions of Article 4 of the Supplementary Protocol (A/SP.l/0l/05) amending the provisions of Article 10 of the Protocol on the Court of Justice (A/P.l/7/91). The contention of the defendant here is that the plaintiff relied on Article 10 (d) of the Protocol as amended whereas that provision is available for the benefit of individuals in actions for the enforcement of their human rights, and not corporate bodies like plaintiff herein. Defendant stated that Article 10 (c) of the Protocol as amended avails itself to both individuals and corporate bodies wherein it is stated thus "Individuals and Corporate bodies in proceedings..." whilst Article 10 (d) .limited itselfto.on1y Individuals. 9. Finally, defendant argued that it did not know how a corporate body like the . plaintiff herein could be a victim of human rights violation. In any case, the issue at hand is not one of a violation of human rights but a pure civil matter. 10. In reply, learned counsel to the plaintiff stated that the exhaustion of local remedies is not a prerequisite for the institution of an action before this Honourable Court and that the plaintiff was properly before the Court and ought to be heard. 11. In respect of the allegation that the plaintiff has no locus standi before this Court in human rights violations, counsel to the plaintiff argued that under Article 9 of the 1991 Protocol as .amended by Article 3 of the 2005 Supplementary Protocol, this Court has jurisdiction over any matter relating to the inte1pretation of the ECOWAS Revised Treaty, Protocols, Conventions and subsidiary legislation of ECOWAS. Further, counsel contended that Article 10(c) of the 1991Protocol as amended provided right of access to individuals and corporate bodies to approach 4