14. The Respondent State prays the Court to: On admissibility, i. Find that at the time the Application was heard, local remedies had not been exhausted before the Applicant filed his Application with the Court; ii. Find that local remedies are available and effective; iii. Consequently, declare the Application inadmissible; iv. Find that the Applicant allowed more than three (3) years to elapse before bringing the case before the Court; v. Declare that the Application was not filed within a reasonable time; and vi. Consequently, dismiss the Applicant’s Application for being filed out of time. On the merits: i. Find that the procedure followed 26/MDGL/DC/SGM/DGCL/SA/011 in SSG17 issuing Order of July 28 No. 2017 suspending the Mayor of Cotonou complies with the laws governing decentralisation in the Republic of Benin; ii. Find that the procedure followed in the dismissal by Decree N°2017380 of 2 August 2017 is regular and compliant with the laws in force; iii. Find and rule that the Applicant’s suspension and removal from office as Mayor of the City of Cotonou does not constitute a violation of his right to free and fair justice; iv. Find that the Applicant left Benin without being forced to do so; v. Find that the Respondent State cannot be held to have violated the right of all citizens to participate freely in the government of their country; vi. Find that the Applicant was not the victim of an attempted abduction by the State of Benin; vii. Find that the State did not violate Article 4 of the Charter; and viii. Consequently, dismiss all of the Applicant’s requests. On the request for provisional measures: i. Find that there is no urgency or extreme gravity; ii. Find that there is no risk of irreparable harm; 5

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