ii.
m.
Article 10(c) and (d) of the Supplementary Protocol (supra);
Article 20 of the Protocol (A/P1/7/91) of the Community Court of
Justice, ECOWAS;
1v. Articles 1, 2, 3, 7, 13(2), 19,26,27,28, and 29 of the African Charter
on Human and Peoples' Rights.
v.
VI.
22.
Articles 33(2) a, 4 and 15 of the Revised Treaty of the ECOWAS;
Article 23 of the Rules of the Community Court of Justice.
She submits that contrary to the position of the Defendants in paragraph
1 of page 5 of their application, the legal qualification and nature of
action of her Application is based and derived as stated above.
23.
The Applicant submits that by the said provisions of the Supplementary
Protocol (supra) she is adequately empowered to file this action which is
therefore not merely administrative or based on the abuse of power by a
staff but an issue that goes to the root and foundation of violations of the
legal regime of the ECOWAS, the Staff Regulations, the fundamental
principles and vision of ECOWAS.
24.
She argues that the analysis of the facts as enumerated by the Defendants
in paragraph II at page 6 of their objection with due respect is
deliberately couched in order to mislead this Honourable Court, and thus
referred the Court to Article 10 of the Supplementary Protocol (supra)
which clearly provides the category and condition for those who may
have access to the Court.
25.
The Applicant states that in line with the objection of the Defendants that
she lacked legal capacity as a staff, she submits that with utmost respect
the Defendants were blind to Article 10(c) and (d) of the Supplementary
Protocol (supra).
8