ORDERS SOUGHT BEFORE THE COURT 19. The Plaintiff prays the Court to make the following orders: a) A Declaration that everyone in the Niger Delta is entitled to the internationally recognised human right to an adequate standard of living, including adequate access to food, to healthcare, to clean water, to clean and healthy environment; to social and economic development; and the right to life and human security and dignity. b) A Declaration that the failure and /or complicity and negligence of the Defendants to effectively and adequately clean up and remediate contaminated land and water; and to address the impact of oil-related pollution and environmental unlawful and commitments Social and a breach on of international as it violates Cultural damage Rights, agriculture human and rights fisheries obligations the International Covenant the International Covenant on on is and Economic, Civil and Political Rights, and the African Charter on Human and Peoples’ Rights. c) A Declaration adequate that monitoring the failure of the of the human Defendants impacts of to establish oil-related any pollution despite the fact that the oil industry in the Niger Delta is operating in a relatively densely populated area characterised by high levels of poverty and vulnerability, is unlawful as it violates the International Covenant on Economic, social and Cultural Rights, the International Covenant on Civil and Political Rights and the African Charter on Human and peoples’ Rights. d) A Declaration that the systematic denial of access to information to the people of the Niger Delta about how oil exploration and production will affect them, is unlawful as it violates the International Covenant on Economic, Social and Cultural rights, the international Covenant on Civil and Political Rights, and the African Charter on Human and Peoples’ Rights. 6|Page