The applicant claims that he paid the Levis Uche & Co law firm the sum of ₦5,000,000
(five million naira) only to sue this process.
4- ON THE APPLICANT'S REQUESTS
The applicant makes the following claims before the Court:
(A) A DECLARATION that the refusal to the applicant's entry into the Republic of Senegal
with his lorries loaded with perishable goods en route to Nigeria on 18 March 2016 by
the defendant is illegal and violates the provisions of Articles 2 and 12 of the African
Charter on Human and Peoples' Rights and Articles 4 (g), the Articles 3 and 27 of the
ECOWAS Revised Treaty which guarantee the right to free movement of persons and
goods within 90 days without a visa in the territory of the Member States.
(B) AN ORDER obliging the defendant to pay to the applicant the sum of thirty-eight
million, four hundred and fifty-four thousand, seventy-two Naira (₦38,454,072.00) only,
being this the normal sale price of said goods in Nigeria after deduction of value
obtained by the sale of the perished goods.
(C) AN ORDER obliging the defendant to pay the applicant the sum of $19,030, being
this the additional cost of feeding and rental of the trucks for an additional period of 33
days.
OR
(D) AN ORDER obliging the defendant to pay the sum of D2,558,400.00 (two million, five
hundred and fifty-eight thousand and four hundred dalasis), being this the cost of
acquisition of the goods after deduction of the sum of D468,000 raised by the sale of
the perished fish and a sum of $36,330 (thirty-six thousand three hundred and thirty
dollars), being this the cost of feeding and hiring the trucks for 63 days.
(E) AN ORDER obliging the defendant to pay a sum of ₦5,000,000 (five million Naira)
only, the legal fees paid by the applicant for the trial of this case.
(F) AN ORDER granting the applicant a sum of $100,000,000 (one hundred million US
dollars) as general and exemplary compensations for psychological trauma, shock and
loss of health due to the action of the defendant.
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