memorandum of understanding which the Respondent signed on 14th December, 2016 with the Maarif Foundation of Turkey and a special representative of the President of Turkey which contained amongst others the following clauses; - ‘At the end of the negotiation an agreement was reached on these points. The Turkey party undertakes, in accordance with the provisions of Law No. 67-21 of 17 June 2016 (voted at the Grand National Assembly of Turkey) for the MAARIF Foundation of Turkey to take over the Bedir and Mehriban Establishments located in Niamey in Niger”. Emphasis ours - ‘The Nigerien party undertakes, first to withdraw or cancel the authorisations, licenses, certificates, rights and prerogatives recognized by means of the law and regulations or conventions in force (Order 96-035 PCSN of 19 June 1996 and its application Decree 201/PCSN/MEN 19 of 19 June 1996)”to Mr. Hayri AVAR acting on behalf of the Bedir Company.’ annexure 12 Alleged Violation 13. The Applicant alleges that the Respondent State violated its right to property, contrary to Article 14 of the African Charter and Article 17 of the UDHR. Reliefs Sought by the Applicant 14. The Applicant prays the Court to: a) Find that under the terms of a memorandum of understanding signed on 14th December 2016 in Niamey between representatives of a foundation called Maarif and the Republic of Niger, it is committed to “… remove or cancel the permit, licenses, certificates, rights and prerogatives recognized by the law and regulations or conventions in force (…)” to Mr. Hayri Avar on behalf of Bedir Company. b) Find that following 5 Decrees of 21st December 2016, the Republic of Niger has withdrawn authorizations for the creation and opening of the establishment and permanent closure of the Bedir School belonging to the Company, BEDIR SARL. 5

Select target paragraph3