30.They contend that the Applicants have not disclosed any actionable wrong by the Respondent that justifies the orders sought by the Applicants. They state further that the assessment of reliefs sought by the Applicants should be based on facts placed before this Honourable Court for which they have put the Applicants to the strictest proof thereof. 31.In concluding the Respondent urges the Honourable Court to dismiss the Applicants’ claim as same are frivolous, vexatious, baseless, incompetent and an abuse of court process b) Pleas in law 32.The Respondent relies on the following laws: i. Section 33 of the Constitution of the Federal Republic of Nigeria; ii. Article 32(4) of the Rules of the ECOWAS Court. c) Reliefs sought 33.The Respondent respectfully urges the Court to consider their argument in opposition to the Applicants’ Application and consequently dismiss this suit for lacking in merit. VII. JURISDICTION Respondent’s Preliminary Objection on Jurisdiction 34.The Respondent filed a Preliminary Objection in accordance with Article 87 of the Rules of Court, contending that the Court lacks jurisdiction to entertain the Application by raising two issues for the determination of the Court: 12

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