23.That 5th –8th applicants have not been in school since resumption of schools as there was no means of paying their school fees 24.That the death of IKyase Chia has made it practically impossible for the family to continue to guarantee the educational needs/rights of the children; thus they are currently being forced to drop out of school The Applicants therefore pray the court for the following; 1. A DECLARATION that the physical assault and gruesome murder of Ikyase Chia on 14th August 2015 by Officer of the Nigeria Police was arbitrary, illegal, unlawful and constitutes a gross violation of the deceased rights to life and respect to dignity of his person as guaranteed and protected under Article 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 their father and sole sponsor of their education) by the police violated the said applicants’ 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 in the circumstances of this case is 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 plaintiffs in two National Dailies. 5. AN ORDER directing the defendants to pay the sum of N500,000,00 ( five Hundred Million Naira) only to the applicants as compensation for violation of the decease rights to life and dignity of his person 6. AN ORDER directing the defendants to pay to the children of the deceased represented by the applicants the sum of N1,000,000,000 ( one Billion Naira) only as compensation for the loss of the sole sponsor of their education to guaranteed their education and enjoyment of their right to education. 5

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