unlawful takeover of communal natural resources and environmental degradation. The Plaintiffs are suing for themselves and on behalf of the Niger Delta people of Nigeria. The Plaintiffs claim that the core Niger Delta Region of Nigeria made up of 6 States in the South-South Geopolitical Zone namely: Edo, Delta, Bayelsa, Rivers, Akwa Ibom, and Cross River States are perpetually under serious environmental attack by the agents and companies purportedly holding Oil Mining Lease (OML) granted to them by the Defendant. That they have been faced with unprecedented degradation, destruction, poisoning, and pollution of the environment through crude oil spills and gas flaring thereby destroying their social and economic life. The spills have destroyed Farmlands and Rivers which is the only source of clean drinking water and also used for fishing. The Plaintiffs further state that the indigenous Communities where these oil and gas explorations are carried out have no input whatsoever in the way and manner the explorations are carried out based on the undemocratic, unlawful, oppressive, repressive, abusive, and discretionary use of Constitutional laws imposed on the underdeveloped and impoverished indigenous owners of the land. The Plaintiffs state that the gas flaring and exploration are done in ways and manner injurious to the Niger Delta region environment thus making such environments a death trap that has led to indiscriminate killings and brutal massacres by the military of thousands of innocent indigenes including old men, women, and children. This 4

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