expression, thus constituting a violation of the right to freedom of expression under the terms of Articles 19 of the ICCPR and 9 of the African Charter. 24. To support its position, the Applicant cited the case law of this Court and other international courts. ON THE RELIEFS SOUGHT BY THE APPLICANT: 25. The Applicant concluded, requesting from the Court: a) A DECLARATION that the Defendant's actions in applying the provisions of Section 24 of the Cybercrime (Prohibition, Prevention, etc.) Act, 2015, to detain and arrest the Applicant's members and associates, violate their rights under Article 9, paragraphs 1 and 2 of the African Charter on Human and Peoples' Rights. a) A DECLARATION that the provisions of Section 24 of Cybercrime (Prohibition and Prevention, etc.) Act, 2015 violate Article 9, paragraphs 1 and 2 of the African Charter on Human and Peoples' Rights, as well as international law. c) A DECLARATION that, with the continued application of Section 24 Cybercrime (Prohibition, Prevention, etc.) Act, 2015 the Defendant has failed to fulfill its obligations under the ECOWAS Revised Treaty and the African Charter on Human and Peoples' Rights. d) AN ORDER which obligates the Defendant to eliminate the provisions of Section 24 of the Cybercrime (Prohibition, Prevention, etc.) Act, 2015 from its legislation. e) A PERMANENT INJUNCTION which prevents the Defendant from continuing to give effect to the provisions of Section 24 of the Cybercrime (Prohibition, Prevention, etc.) Act, 2015. f) OTHER CONSEQUENTIAL ORDERS that this Court may consider fit for the purpose. ON THE ARGUMENTS PLEADED BY THE DEFENDANT STATE 26. The Defendant State, in its defense, admits that it approved the law entitled “Cybercrime (Prohibition, Prevention, etc.) Act, 2015” with 59 articles and that the 7

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