conditions they state is as bad as the death penalty itself, and constitute a violation of established international human rights laws. 13.They therefore seek the intervention of the Court to order their release from the Prison. 14.The Applicants’ case is also supported by a 22 paragraph affidavit sworn to by Mr. Jude Arthur Angel, a member of staff of the first Applicant. b) Pleas in law 15.The Applicants rely on the following laws: i. Articles 2, 5 and 7 of the African Charter on Human and Peoples’ Rights; ii. African Charter on Human and Peoples’ Rights (Ratification and Enforcement) Act. 1\Cap A9, Vol 1 Laws of the Federation of Nigeria 2004; iii. Article 4 of the Revised Treaty of the Economic Community of West African States (ECOWAS). c) Reliefs sought 16.The reliefs sought by the Applicants are as follows: i. A Declaration that the Applicants have suffered extreme mental torture, inhuman and degrading condition having been kept on death row for more than 15 years and without access to adequate medical treatment. ii. A Declaration that the Applicants by virtue of age and long stay on death row and presently suffering from chronic medical condition are entitled to be released forthwith from detention. 6

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