111. That similarly, the Applicants, former employees of the ECOWAS Court of Justice, have suffered losses due to the observed delay in payment and they seek redress. 112. That the Applicants are well grounded in claiming default interest. 113. That the damages they suffered open up the right to the payment of compensation; 114. That under the terms of the employment contract, the Defendant's yearslong failure to pay the allowances claimed is attributable to the Employer who must assume its responsibility. 115. That by choosing not to pay the due allowances, ECOWAS Commission has committed a fault which has made the financial situation of the Applicants more vulnerable with regard to their family responsibilities and the situation of some already retired. 116. That the failure to pay the allowances created in the Applicants a lack of support for their health, which also created a huge psychological distress. 117. They conclude that the conditions are met to order the Defendant to pay them damages. 118. That the former co-workers of Judges previously collectively claimed payment, addressing respectively to the Commissioner for Human Resources, the President of the Court of Justice and the President of the ECOWAS Commission, but unfortunately without success (Exhibit X). 119. Similarly, former ECOWAS military officers have also approached the ECOWAS authorities for the payment of their allowances, without success (Exhibit Y). b. Pleas in Law 18

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