The Applicant’s Response to the Objection on locus standi 17. The Applicant in response to the objection that it lacks locus standi to institute this case argued that this is a narrow and erroneous interpretation of the treaty provisions. The Applicant relied on the case of Les Établissements VAMO and Paschal Kuekia v Republic of Benin, Judgment No ECW/CCJ/JUD/12/15 of 20 April 2015, where the Court held that one of the Applicants in that case, which was a legal entity, had personal interests in bringing the action before the Court and dismissed the objection of the Respondent States claiming that it was not a victim. The Applicant reiterated the fact that the instant case relates to the violation of its rights to property; a right which avails a legal entity. It therefore prays the Court to assume jurisdiction on the Application, reject the Respondent’s preliminary objection and declare the application admissible. Respondent State’s Defence on the merits 18. On the 14th March 2017, the Respondent filed its defence to the Applicant’s application wherein they asserted that sometime in 2016, an inspection tour was carried out by the Ministry of Education on the use of licenses granted for the establishment and opening of the Applicant’s schools. That the investigation carried out revealed a number of instances of misuse of the license. That the Applicant’s company which was a one-share holder company became subject of two ownership transfers without prior authorization by the Government. They further argued that the managers of the schools were appointed by a notarized deed in addition, and finally that the Applicant did not co-operate with the inspectors during the said inspection. 19. They concluded that the inspection revealed that the Applicant violated Articles 4,6,8,9,15,17,18,19,21,22,23 and 28 of Decree No. 96201/PCSN/MEN of June 1996 establishing the application modalities of the Order governing private education in Niamey and that the grant of license was preconditioned on compliance with the listed articles in the said Decree. In view of the above and with reference to the orders upon which the authorization was granted, the Respondent by a letter dated 28 th December 7

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