Justice, for the purposes of pleading that it may please the Court to declare as
follows:
That the Honourable Court has jurisdiction to adjudicate on the case;
That the Application is admissible;
That the Republic of Senegal violated Karim Meissa Wade’s right to participate
freely in the public affairs of his country;
To adjudge that the Applicant’s right to vote is violated and that his right of
eligibility to stand for election in the 24 February 2019 election is violated;
To order the Republic of Senegal to restore his name immediately on the
electoral roll for the 24 February 2019 election and to issue him with a voter’s
card;
To adjudge that the Senegal Electoral Code as amended by Law No. 2018-22 of
4 July 2018 in its Article L57 of the Electoral Code is a violation of the right to
free participation in elections;
To order the Republic of Senegal to remove all the obstacles to the Applicant’s
participation in the Presidential elections of 24 February 2019 originating from
the said amendments to the law;
To find that Karim Meissa Wade’s right to effective remedy before the law courts
is violated;
To order the Republic of Senegal to strictly observe the international
instruments binding on it in regard to respect for Karim Meissa Wade’s rights;
and
To ask the Republic of Senegal to bear the costs.
On the same day as his Initiating Application, Karim Meissa Wade filed before
the Court an Application for Expedited Procedure, seeking the same remedies.
On 18 December 2018, the Republic of Mali, represented by the State Judicial
Officer and assisted by Maître Yérim Thiam and four other lawyers, raised the
question of prima facie incompetence of the Court.
Relying on his written pleadings and on the defence put up by his lawyers Maître
Ciré Clédor Ly and three others, Karim Meissa Wade contended that since the
date for the presidential elections in Senegal was fixed for 24 February 2019, in
his capacity as the candidate for the opposition political party known as Parti
Démocratique Sénégalais (PDS), on 16 April 2018, he went before the
Translator: E. Nkansah 3