a.
There
is no paragraph in the narration filed in support of the substantive
application which shows that the 1" Plaintiffis a juristic
and only consists of member
person
duly
registered
countries of ECOWAS.
b.
The 1” Plaintiff lacks the Jocus stand/ to institute this action.
CG
The
2™ and 4" Plaintiffs’
claim is premature
and cannot be maintained
for it does not disclose any cause of action.
d.
The 3" Plaintiffs' claim is statute barred
&
The
Plaintiffs/Respondents
suit
before
this
court
is an
affront
to the
internal sovereignty of the Defendant/Applicant.
The Defendant supported the above objections with legal arguments and decided
authorities.
In response to the objection raised by the Defendant, the Applicants contends that
the 1" Applicant is a legal person recognized and registered under Senegalese law.
A proof of official registration was therefore attached and marked "Annex 1", The
Applicants further pointed out that this Court has already granted standing to the |"
Applicant in a previous proceeding; the 1" Applicant under its alternative name '
International Federation of Journalists Africa'- was the 3rd Applicant in the recent
case of Hydara V. The Gambia, ECW/CCJ/APP/30/1 1.
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