to continue with the educational needs of his children; thus they are currently forced to drop out of school. That the unlawful deprivation of their father’s right to life by the Nigerian Police has left an attendant effect on the rights to education of the 5th-8th Plaintiffs as guaranteed by Article 17(1) of the African Charter on Human and Peoples Rights. The Plaintiffs therefore prays for the following orders: 1. A DECLARATION that the physical assault and gruesome murder of Ikyase Chia on 14th August 2015 by officers of the Nigerian police led by Inspector Benjamin Yankyaa was arbitrary, illegal, unlawful and constitute a gross violation of the deceased rights to life and respect to dignity of person as guaranteed and protected under Articles 4 and 5 of the African Charter on Human and Peoples' Rights. 2. A DECLARATION that the 5th-8th Applicants as well as the Applicants described as minors have rights to education which the killing of Ikyase Chia (who was the father and sole sponsor of their education) by the police violated the said applicant’s rights as protected under Article 17(1) of the African Charter on Human and Peoples' Rights. 3. A DECLARATION that the failure of the Defendants to investigate, discipline and prosecute the police officers involved in the unlawful arrest and killing of Ikyase Chia in the circumstances of this case is a violation of the applicants’ rights as enshrined in the African Charter on Human and Peoples Rights. 4. AN ORDER for an independent inquiry into the killing of Ikyase Chia and publication of a letter of apology to the Applicants in two National Dailies. 10

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