were sensitized on the need to maintain peace and order within the region and eschew segregation and sectarian sentiments. That they cannot be held responsible for any ethnic crimes committed by unidentified and unknown persons which constitutes a breach and these perpetrators are not connected or known to the Respondents or any of its agencies. 11. That the indigenes of Agatu community who are farmers were also known to have triggered the violence by carrying out a reprisal attacks on the herdsmen and they are not entitled to any compensation for the direct consequences of their action. That the perpetrators of these criminal atrocities are unknown to any of the Respondents, and no tacit approval was given by the Respondents to any criminal atrocities taking place between the two ethnic groups. That no group or individual anywhere except security personnel are allowed to own ordinary weapon and none of the attacks carried out was predicted by any of the Applicants giving the claim that the Respondents have neglected or refused to take appropriate steps to protect the Applicants. That they never received any facts of predictable attacks and the location or any confessional statement from anyone between the two warring ethnic groups. 12. That they have not failed in their efforts and responsibilities to protect the Agatu community in Benue state and Nigeria at large. That the 2nd Respondent gave an order to the security officers to the effect that the perpetrators who carried out attacks on all communities in Nigeria must be investigated, arrested and prosecuted. That the Applicants have not disclosed any actionable wrong to them by any of the Respondents to justify the Court making the orders sought. That the Applicants’ claim for damages is not substantiated by facts. That granting any of the reliefs sought by the Applicants will result in bad blood while opening a floodgate to similar claims from other ethnic groups in the state. 13. Annexed to their statement of defence is a preliminary objection on the following grounds: 1. The Community court of justice, (ECOWAS) lacks the requisite jurisdiction to hear this matter. 2. Lack of cause of action against the 1st-4th Respondents. The 5th and 6th Respondents in response to the Applicants application filed a preliminary objection on the following ground that the Court lacks jurisdiction 7

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