(;H~:JACHPR ~, a.a:UD .:, African Commission, on Human and Peoples RIghts Human Rights our Collective Responsibility because of the arbitrary manner in which the Respondent State has put its plans into effect. 101. The Complainants submitted that they are "non-participants" in the Gibe III and Kuraz and have been offered no share in the benefits that will accrue from sugar cane production on their grazing pasture. 102. The Complainants also submitted that the Respondent State's claim that all displaced persons have been or will be given substitute plots of land equal in size to their previous holdings and proportionate compensation does not justify a breach of Article 21(1) of the African Charter. .'.:' (iii) Alleged violation of Articles 22(1) of the Charter 103. The Complainants submitted that both Gibe III and Kuraz will have major impacts on their lives and that the Respondent State's failures to conduct any (or a proper) impact assessment of either Project and to seek or obtain their free, prior and informed consent to either of them are violations of the Complainants' right to development under Article 22(1) of the African Charter. 104. The Complainants submitted that when a large-scale development is likely to have a major impact on the territory of a particular community, the State has to obtain the community's free, prior and informed consent to it. 105. The Complainants submitted, including in the Addendum to Complainants' Written Brief, that evidence of the Respondent State's breaches of Article 22(1) of the African Charter is summarised at paragraphs 44,55 to 68 and 81 to 90 of their written Submissions and they also rely on the Respondent State's failure not only to obtain their free, prior and informed consent to not undertake Gibe III and Kuraz but also to consult them about both Projects before committing itself to it. (iv) Alleged violation of Article 24 of the Charter 106. The Complainants submitted that Gibe III and Kuraz will deny them an environment which is either satisfactory or favourable to their development. And that in breach of Article 24 of the African Charter, the Respondent State has failed to conduct any proper study of the environmental impact of either Project or of the risks that the projects pose to public health.