d. That the Government should establish a Mobile Police Barracks between Zonkwa and Kafanchan as well as Gonin Gora both in Kaduna State. 48. The recommendations were adopted by the Federal Executive Council which directed the Federal Ministry of lands and Housing to assess the reported losses and damage to properties in all affected states. Following the recommendations of the Sheikh Ahmed Lemu Panel, the Federal Government approved the release of the sum of N5, 747,694,780.00 to the nine of the affected States of the Federation. 49. The Government also took steps to establish proactive security measures to address the flashpoints in the State, including the enhancement of the State Security Outfit, (Operation Yaki). This was a comprehensive security arrangement to protect lives and properties in the various communities. The Government established the Bureau for Religious Affairs (Christian and Islamic matters) and Inter-Religious Harmony Committee at the State and Local Government levels. This was an institutional arrangement aimed at addressing negative Religious activities in Kaduna State. The Federal Government also established different initiatives to create employment for example, You Win, and public works programmes, Youth in Agric Business for Nigeria, the SURE-P programmes and other job creation programmes in Housing and other sectors. 50. The Federal Government following the recommendation of the panel directed the Inspector-General of Police to establish Mobile Police Barracks between Zonkwa and Kafanchan as well as Gonin Gora both in Kaduna State. Respondents submit that the above are responsive and noble acts expected of a democratic Government; and urge the Court to resolve this issue in favour of the Defendants, to hold that the Federal Government of Nigeria did not fail in its duty under the Constitution of the Federal Republic of Nigeria and the various Statutes, and refuse the reliefs sought by the Applicants. 51. Orders Sought by the 1st and 2nd Defendants. 52. Respondents urge this Honourable Court to hold as follows: 1. That it cannot be said that the Respondents failed to provide protection and exercise due diligence before, during and after the post-election riot of 2011 in Kaduna South. 2. That the Federal Government of Nigeria promptly took steps to intervene in the crises by deploying security operatives within a reasonable time and by taking step 13

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