Human Rights our Collective Responsibility Merits Summary of the parties' submissions A. Complainants=submissions 77. The arguments below are the submissions of the Complainants, having regard to their written submissions on the merits (including the Addendum to Complainants' Brief on the Merits) dated 4th September 2015, the additional observations dated 26th January 2016, the further observations dated 31st August 2016 and the latest information update on the projects, together with all the bundles of documentary evidence respectively attached to their submissions before the Commission. 78. The Complainants submitted that the Respondent State, in pursuit of the Gibel Gibe III Dam Project and the Kuraz Sugar Project ("Gibe III and "Kuraz"), has repeatedly violated the rights of the Complainants protected under Articles 20(1), 21(1),22(1) and 24 of the African Charter. 79. The Complainants submitted that the Respondent's arguments, that the claims in this Communication are designed to obstruct its development or advance a romanticised ideal of the Lower Omo people that has no place in a contemporary society, are misconceived. They submitted that the Lower Omo peoples are not opposed in principle to development or dams, and do not want or expect to be insulated from modernity. However, they submitted that contrary to what proponents of large development projects often argue that development would trickle down to the indigenous communities caught in the slipstream, projectaffected communities are most often the principal Iosers.A 80. The Complainants submitted in the context of the Lower Omo that the sugar cane project will take the best grazing land and leave the Complainants dependent on food aid, earnings from casual work on the plantations, and the sale of their photographs to tourists; and that they will not be lifted out of poverty, but driven ever deeper .into it. 81. The Complainants submitted that only if they are able to decide for themselves whether, when and how quickly they want to change their way of life is there any prospect that they will survive, let alone profit from, the huge projects now underway in the Lower Omo. 21 Cemea, Michael. Reforming the foundations of involuntary resettlement: introduction, in LV",:I'>'i'I.\I'1 and benefit-sharing. Oxford: Oxford University Press, 2008. N: O!llall of the AfriGan C:' '>.j Union ',\,,,,,,,;,,': 16