ii. A Declaration that the Applicants by virtue of age and long stay on death row and presently suffering from chronic medical condition is entitled to be released forthwith from detention. iii. An Order for immediate release of the Applicants from detention forthwith. iv. A Declaration that the consistent and continued denial of the right to adequate medical attention and the detention of the Applicants in prison under dehumanizing and harsh conditions is in violation of the Constitution of the Federal Republic of Nigeria and Articles 1,2,3,4,5,7 and 26 of the African Charter on Human and People’s Rights; v. An Order directing the Defendant to pay a monetary compensation of 20,000,000 (Twenty Million naira) each to the Applicants for damages suffered as a result of long years they have been kept in prison under cruel degrading and inhuman condition. vi. An Order for reparations, including physical, psychological, social and economic rehabilitation in respect of the violation of the Applicant’s human rights. And the cost of this suit which is accessed at N5, 000,000.00 (Five Million Naira). vii. An Order directing the Defendant to faithfully and fully implement its obligations under its own constitution and African Charter on Human and Peoples’ Right as well as resolutions on Moratorium on executions adopted recently by both the African Commission on human and People’s Rights and the Third Committee of the UN General Assembly. 9

Select target paragraph3