I ASTO LAW JURISDICTION OF THE COURT AND ADMISSIBILITY OF THE APPLICATION Arguments of the Applicants 11. The Applicants submit that the Application is admissible on the grounds of Articles 9(4) and 10 of the Protocol on the Court as amended by the 19 January 2005 Supplementary Protocol, which provide respectively: "The Court has jurisdiction to determine cases of violation of human rights that occur in any Member Staten... "Access to the Court is open to ... individuals on application for relief for violation of their human rights". They further submit that since human rights are inalienable, timeless and sacred, they limitation whatsoever. cannot suffer any form of Arguments of the Republic of Togo 12. The Republic of Togo argues that it is a cardinal principle in judicial procedural law that any person who initiates an action in court shall justify his locus standi and that one of the essential conditions is a clear, obvious and precise identity of the applicant. It further argues that the _ _ court before which the case_ !s brought shall ensure that the (cant(s) really exist(s). But, as contends the Republic of Togo, the identification of the Applicants is imprecise, and this springs serious doubts as to whether the Applicants truly exist or not. 13. Furthermore, the Republic of Togo argues that the instant suit was filed upon the initiative of the Coalition of Associations Against Impunity in Togo (CACIT), whose President is no . other person than Maitre Zeus Ajavon. The Republic of Togo alleges that CACIT is indeed a political organisation whose links with political parties publicly known. It affirms, on that ground, that all forms of political intrigues are possible, towards coming up with a schedule of activities for justifying the finances engaged. i_n or for vilifying the Republic of Togo, the latter entertaining fea r s that the national and regional judicial institutions may thereby be manipulated by way of intrigues in the court procedur e. 5

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