ix. Order the Respondent State to pay reparations in the amount of Fifty Million Tanzanian shillings (TZS 50,000,000) for costs incurred by the Applicant on transport; x. Order the Respondent State to pay the Applicant reparations in the amount of One Hundred Sixty-Six Million and Five Hundred Thousand Tanzanian Shillings (TZS 166,500,000) as compensation for affecting his properties. 13. With regard to jurisdiction and the admissibility of the Application, the Respondent State prays the Court to order that: i. The Court has no jurisdiction to act as an Appellate Court towards the grounds of appeal pronounced by the Applicant; ii. The Applicant has not met the admissibility requirements as provided by Rule 39(1) of the Rules of Court;3 iii. The Application be declared inadmissible; iv. The Application be dismissed in accordance with Rule 38 of the Rules of Court;4 v. The cost of the Application be borne by the Applicant. 14. With regard to the merits of the Application, the Respondent State prays the Court to order that: i. The Respondent State did not violate the provisions of Article 3(2) and 5 of the Charter against the justices and rights of the Applicant; ii. The Application be dismissed for lack of merits; iii. The Applicant continues to serve his sentence; iv. The Applicant’s prayers be dismissed; v. The cost of this Application be borne by the Applicant. 15. In Response to the Applicant’s submissions on reparations, the Respondent State prays the Court to: 3 4 Corresponding to Rule 49(1) of the Rules of 25 September 2020. Corresponding to Rule 48 of the Rules of 25 September 2020. 5

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