teq},q i. Objection on the ground that the Court is being asked to sit as a court of first instance 26. The Respondent State submits that the Applicants are asking the Court to act as a court of first instance and deliberate over matters that have never been adjudicated on by its municipal courts. The Respondent State further submits that the Court does not have jurisdiction to sit as a court of first instance. ln support of its contention, the Respondent State points out that all the Applicants are challenging the constitutionality of section 51 of the PrisonsAct, 1967; sections 445 and 446 of the Prison Standing Orders and also the Parole Act. Additionally, the First Applicant and the Seventh Applicant, are also challenging the constitutionality of sections 4(c) and 5(a) of the Minimum Sentences Act. All the Applicants are also alleging a violation of Article 13 of the Respondent State's Constitution. It is the submission of the Respondent State that ail the Applicants have never raised any of these challenges before its domestic courts. 27.The Applicants, in their Reply, contend that the Court has jurisdiction as per Article 3 of the Protocol and Rule 26(a) of the Rules. lt is the Applicants' submission that the essence of their prayers give the Court jurisdiction since their Application is inviting the Court to review the conduct of the Respondent State in light of the international standards and human rights instruments that it has ratified. 28. The Court notes that the crux of the Respondent State's objection is that it is being asked to sit as a court of first instance. Atthough the Respondent State has raised this objection as relating to the Court,s material jurisdiction, the Court notes that the Respondent State has, essentially, argued that the matter is not competenfly before the Court since all the Applicants never attempted to activate domestic mechanisms to remedy their grievances. 10 V -\ e-' \trN\a"