in the rally were locked out thus preventing them from gaining access to the venue. Consequently, the protest could not take place as planned. 10. It is their contention that the Respondent failed to promptly communicate the decision prohibiting the assembly to the Applicants. They submit that the lock out order of the Respondent infringed on their rights, their best interest and that of the general public. Furthermore, the grounds for the interference were not clear, it was overly broad and vague not being specific in regards to the nature nor the duration. 11. They further alleged that the Edo State Government banned the gathering of members of Nigeria Council of Women Societies in May 2021 through a public announcement. They submit that the ban was not in accordance with the principles of legality or legitimate public purpose and was unnecessary and disproportionate to achieving any meaningful purpose within a democratic society. 12.In conclusion, the Applicants submit that the Respondent violated their right to freedom of association and assembly provided by Articles 10 and 11 of the African Charter; Article 21 of the ICCPR and Section 40 of the 1999 Constitution of the Federal Republic of Nigeria (as amended), as well as the African Commission on Human and Peoples’ Rights (ACHPR) Guidelines on Freedom of Association and Assembly in Africa 2017 and Guidelines for Policing of Assemblies by Law Enforcement Officials in Africa 2017. 13.The Applicants supported their claims with Exhibits A (Applicant’s certificate of registration), B, C, D (Photographs at the scene of the event), E, F, G (media reports of the event by Daily Trust, Sun News online and 5

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