discovered they made a mistake. The applicants are being economical with the truth because they cannot claim not to have noticed their mistakes after going through the various defences filed by the Respondents. The Supreme Court has in a plethora of authorities severally held that when issues have been joined, the proper order to make in an application by a Plaintiff or counterclaimant for withdrawal is dismissal.” “The Applicants’ application is an Originating Application brought under the African Charter on Human and Peoples Rights and the Constitution of the Federal Republic of Nigeria 1999 as amended where all documentary evidence have been front loaded and oral evidence may not be called.” - 15 “We humbly urge the court to exercise its discretion in favour of the Respondents in this case by dismissing the suit with substantial cost.” 5.5. PLAINTIFFS’ REPLY ON POINTS OF LAW 5.5.1. In response to the various Counter Affidavits of the Respondents opposing the Applicants right to withdraw and/or discontinue their suit, the Plaintiffs/Applicants then filed two separate but similar (almost repetitive) responses/REPLIES on POINTS of Law, in rejoinder to the issue raised by the said Respondents. Likewise, we herein reproduce the full texts of the Applicants rejoinder/ie. REPLY on POINT of LAW: “REPLY ON POINT OF LAW TO APPLICATION OF THE 1 ST, 2ND, 6TH AND 7TH RESPOND ENT S AGAINST APPL ICANTS’ MOTION FOR LE AVE TO DISCONTINUE THIS SUIT” “INTRODUCTION” “On the 14th day of September 2015, the Applicants filed their application for LEAVE of this Honorable Court to allow them withdraw/discontinue this suit based on the reasons stated therein including but not limited to the awareness or better understanding garnered by Counsel from the 7th Judicial Retreat of this Honorable Court at Owerri, Imo State as it concerns proper parties before the Court. On the 19th day of October, the 1st, 2nd, 6th and 7th Respondent their “COUN TER AFFID AVIT IN SUPPOR T OF ARGUMEN T AGAINST THE APPLICANTS MOTION ON NOTICE FOR WITHDRAWAL/OR st nd th DISCONTINUA NCE” Obviously, the 1 , 2 , 6 and 7th Respondents do not understand applicants’ application as they misconstrued it to be withdrawal/discontinuance simpliciter. It is not, it is application for leave……”

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