investigation and punish perpetrators. The Applicants contends that the failure of the
Respondent to exercise due diligence and professionalism particularly on the part of
its security agents’ amounts to violation of the rights to life of their members and
dependants killed under pretext of election violence.
25. The Applicants whose properties were destroyed and the deceased like every
citizen of the ECOWAS are equal before the law and are entitled to equal protection
of the law as enshrined in Article 3 of the African Charter of Human and Peoples
Rights. The Applicants have a right to National and International peace and security
as enshrined in Article 23 of the African Charter of People and Human Rights.
26. Applicants argue that the actions and inactions of the Respondent constitute a
flagrant violation of the Applicants rights listed in the Initiating Application in
paragraphs 16 -18 as guaranteed by the African Charter of People and Human Rights
and 19 -20 as guaranteed by other International Human Rights Instruments to which
Nigeria is a signatory.
27. Order and Reliefs Sought by Applicants
i. A DECLARATION that failure of the Federal Government of Nigeria, their
servants, agents and privies to provide adequate and timely security for all that were
killed in Zonkwa, Fadan Daji, Gidan Maga, Daddu, Farman, Madakiya, Matsirga,
Samara Kataf, Maraban Rido, and Unguwan Rimi all within southern Kaduna
before, during and after the April 2011 Presidential Election is unlawful as it
constitute a violation of Nigeria’s international Human Rights obligations and
commitments to respect, promote and ensure the right to life, as guaranteed under
the African Charter of People and Human Rights and the UN International Covenant
on Civil and Political Rights to which Nigeria is a state party
ii. A DECLARATION that the failure of the Federal Government of Nigeria, their
servants, agents and privies to promptly arrest, investigate and prosecute particularly
in the entire Zonkwa, Fadan Daji, Gidan Maga, Daddu, Farman, Madakiya,
Matsirga, Samara Kataf, Maraban Rido, and Unguwan Rimi the perpetrators of the
acts which led to the brutal killing of over 800 (Eight Hundred) Muslim members
of southern Kaduna in Kaduna State represented by the Applicants herein and
displacement of over 60,000 (Sixty Thousand) others is unlawful as it violates their
rights to life, right to security, right to dignity of human persons and equal protection
of the law as guaranteed under the African Charter of People and Human Rights; the
UN International Covenant on Civil and Political Rights and UN International
Covenant on Economic, Social and Cultural Rights to which Nigeria is a state party.
7