their salaries to which they built canteens across the 36 states of the federation. That the said canteens were sold by the Respondent with no compensation paid to the Applicants. 7. That most of the landed properties in which the said NITEL/MTEL were situate across the states belonged to some of the Applicants and same was sold by the Respondent without compensating the Applicants despite repeated demands. That the Supreme Court’s decision for the Applicant’s to be paid 5 years pension buy out is unconstitutional and contrary to international laws of human rights. That the acts of the Respondent in failing to pay to the Applicants all their entitlements amounts to a flagrant violation of their human rights. 8. WHEREUPON THE APPLICANTS SEEK THE FOLLOWING RELIEFS/ORDERS: 1. A DECLARATION, that 5 years pension buyout, Respondent paid to the Applicants as their entitlement, is a flagrant violation of a continuous right of the Applicants to section 173, 1,2,3, & 210 of the 1999 Constitution of Nigeria and the Articles mentioned above which provide for life pension to the Applicants and other entitlements. 2. A DECLARATION that the purported request by the Pension Transmission Arrangement Directorate (PTAD) agent of the Respondent, requesting the Applicants to submit their documents for a monthly payment of pension without other entitlement claims of the Applicants herein pleaded in this application is a flagrant violation of their rights as provided in sections 173, 1, 2, 3 & 210 of the 1999 Constitution of Nigeria and the Articles mentioned above. 3. A DECLARATION that the Applicants’ are entitled to 200 Billion Naira only, as their pensionable retirement benefit payable in bulk since the NITEL/MTEL have being sold by the Respondent who employed the Applicants as workers under permanent and pensionable conditions of service as provided in section 173, 1, 2, 3 & 210 of the 1999 Constitution of Nigeria, and not only monthly pension as prescribed by the Respondent. 4. A DECLARATION that the Applicants are entitled to be paid their federal mortgage contribution fund deducted at source by the Respondent from their salary when in active service of the Respondent. 4

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