ii. Based on the precedent awards ordered in the Zongo Case, supra, we pray the Court grants a sum based on the current Tanzanian average yearly minimum wage of USD 1,593 multiplied by the 10 years the Applicant has been imprisoned under death row, amounting to a total of USD 17,523, with an additional uplift of USD 10,000 in recognition of the exceptional suffering the Applicant endured due to her imprisonment on death row; or iii. Based on the precedent awards ordered in the Zongo Case, supra, we pray the Court grant a sum based on the Value of a Statistica Life (VSL) in Tanzania at USD 158,000 given a life expectancy of approximately 65 years (Income Elasticities and Global Values of a Statistical Life, Journal of Benefit-Cost Analysis (2017), p. 247), amounting to a value of USD 24,308 for the 10 years of life the Applicant lost due to her imprisonment, in addition to an additional uplift of USD 10,000 in recognition of the exceptional suffering the Applicant endured due to her imprisonment on death row. * 154. The Respondent State submits that there is neither violation nor any harm which it committed against the Applicant. Further, that there is neither proof that substantiates the causal link between the harm suffered and the purported violation of the Applicant’s rights. *** 155. The Court recalls its established case-law where it has held that moral prejudice is presumed in cases of human rights violations and the quantum of damages in this respect is assessed based on equity, taking into account the circumstances of the case.53 The Court has, thus, adopted the practice of granting a lump sum in such instances.54 53 Norbert Zongo and Others v. Burkina Faso (reparations), § 55; lngabire Victoire Umuhoza v. Rwanda (reparations), § 59; Christopher Jonas v. United Republic of Tanzania ACtHPR, Application No. 011/2015, Judgment of 25 September 2020 (reparations), § 23. 54 Lucien lkili Rashidi v. Tanzania (merits and reparations), § 119; Minani Evarist v. United Republic of Tanzania, (merits and reparations) (21 September 2018) 2 AfCLR 402 (merits), § 84-85; Armand Guehi v. Tanzania (merits and reparations), § 177; Christopher Jonas v. Tanzania (reparations), § 24. 44

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