The Defendant in response to the Plaintiff’s application states that, the officers on duty on the said date requested the Plaintiff to present an identification at the checkpoint, he refused to be checked claiming that he is an ECOWAS citizen and based on the provisions on free movement of persons and goods he does not need to present any identification. That the Plaintiff rather than submitting his identification resorted to shouting and tried to force his way into its territory. That a security officer who heard what was going on quietly led the Plaintiff to the office of the Head of the Brigade and requested that he should instead show his passport to the Head of the Brigade but still the Plaintiff refused to submit it. The Head of Brigade advised the Plaintiff to lodge a complaint with the border police instead of engaging the security officers in a "brawl". The Plaintiff then submitted his passport to the Brigade head who ordered that his passport be stamped and returned to the Plaintiff to continue with his journey. That the Plaintiff left the border post in a good state of health both physically and mentally. That they were surprised when they received a notice that the Plaintiff lodged a complaint against its officers claiming that he was given a beating of a life time and his passport seized by the security officers. After they received the complaint through the INTERPOL, the Beninois police cooperated in carrying out the investigation. In the course of the investigation, both 7