investigation and punish perpetrators. The Applicants contends that the failure of the Respondent to exercise due diligence and professionalism particularly on the part of its security agents’ amounts to violation of the rights to life of their members and dependants killed under pretext of election violence. 25. The Applicants whose properties were destroyed and the deceased like every citizen of the ECOWAS are equal before the law and are entitled to equal protection of the law as enshrined in Article 3 of the African Charter of Human and Peoples Rights. The Applicants have a right to National and International peace and security as enshrined in Article 23 of the African Charter of People and Human Rights. 26. Applicants argue that the actions and inactions of the Respondent constitute a flagrant violation of the Applicants rights listed in the Initiating Application in paragraphs 16 -18 as guaranteed by the African Charter of People and Human Rights and 19 -20 as guaranteed by other International Human Rights Instruments to which Nigeria is a signatory. 27. Order and Reliefs Sought by Applicants i. A DECLARATION that failure of the Federal Government of Nigeria, their servants, agents and privies to provide adequate and timely security for all that were killed in Zonkwa, Fadan Daji, Gidan Maga, Daddu, Farman, Madakiya, Matsirga, Samara Kataf, Maraban Rido, and Unguwan Rimi all within southern Kaduna before, during and after the April 2011 Presidential Election is unlawful as it constitute a violation of Nigeria’s international Human Rights obligations and commitments to respect, promote and ensure the right to life, as guaranteed under the African Charter of People and Human Rights and the UN International Covenant on Civil and Political Rights to which Nigeria is a state party ii. A DECLARATION that the failure of the Federal Government of Nigeria, their servants, agents and privies to promptly arrest, investigate and prosecute particularly in the entire Zonkwa, Fadan Daji, Gidan Maga, Daddu, Farman, Madakiya, Matsirga, Samara Kataf, Maraban Rido, and Unguwan Rimi the perpetrators of the acts which led to the brutal killing of over 800 (Eight Hundred) Muslim members of southern Kaduna in Kaduna State represented by the Applicants herein and displacement of over 60,000 (Sixty Thousand) others is unlawful as it violates their rights to life, right to security, right to dignity of human persons and equal protection of the law as guaranteed under the African Charter of People and Human Rights; the UN International Covenant on Civil and Political Rights and UN International Covenant on Economic, Social and Cultural Rights to which Nigeria is a state party. 7

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