d. An Order mandating and compelling Togo to take all necessary measures to guarantee measures of non-recurrence in order to prevent the same violations occurring again in future; e. An Order mandating and compelling Togo to effectively enact and implement laws, regulations and safeguards in order to meet its obligations with respect to the right to freedom of expression under international human rights law, including under the African Charter, ICCPR and the Revised ECOWAS Treaty; f. An Order mandating and compelling Togo to issue adequate reparations, including restitution, compensation and measure of satisfaction to the Applicants, to be specified and submitted to this Honorable Court in due course; and g. Such further order/s remedy and/or relief as this Honorable Court may deem fit to grant in the circumstances. D. The Respondent’s Defense 12. The Respondent states that there were protests since the 17th August 2017 and that the same were orchestrated by the opposition party, Le Parti National Panafracin (PNP) in conjunction with other political groups. 13. The Respondent also avers that even though freedom of association and peaceful demonstration is guaranteed by the constitution of Togo of 14 th October 1992 the same is conditioned by law. That Law no. 2011-010 of 16 May 2011 was a means of giving effect to the constitutional provision which enables administrative authorities to regulate all public manifestations, and that the Respondent had submitted that it be adopted. That having made some observations of the itinerary proposed by the organizers an alternative itinerary was proposed by the authorities. 14. The Respondent avers that the PNP disregarded the proposal of the authorities and proceeded to carry on with its original proposal which resulted in skirmishes. That the opposition party formed a coalition with other political parties and demanded for a return to the Togolese Constitution of 27th September, 1992 which 5|Page

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