x.
Hold that his appeal to the public prosecutor was not effective and that
his case was not heard insofar as the trial never took place and insofar
as to date, the judiciary and the Presidency of the Republic have not
written to inform him of the course of action to be taken, and insofar as
no tangible action was taken on the matter.
xi. Hold that in the third case, the Beninese courts violated Articles 8 and
10 of the Universal Declaration of Human Rights and Article 7 of the
African Charter on Human and Peoples’ Rights.
xii. Find that the Respondent State is responsible for many internationally
wrongful acts.
xiii. Hold that the Beninese State is under obligation to pay him full reparation
for the harm it caused him, with each of the violations giving the right to
compensation.
xiv. Order the Respondent State to pay him an amount of One Million
(1,000,000) CFA Francs as reparation for material harm;
xv. Order the Beninese State to pay him an amount of Five Billion
(5,000,000,000) CFA Francs as moral reparation;
xvi. Order the State of Benin to pay, within six (6) months of delivery of the
judgment, all amounts awarded in the judgment to be delivered, failing
which the Beninese State shall pay default interest calculated on the
basis of the applicable rate of the Central Bank of West African States
(BCEAO) throughout the period of delay and until full payment of the
sums due.
13. The Respondent State prays the Court to:
i.
Find that the case relates to a private legal dispute between individuals;
ii.
Find that the Application does not seek to challenge the violation of
rights guaranteed by the Charter and other international legal
instruments;
iii.
Find that the Application was not filed after exhaustion of local
remedies;
iv.
Find that the Application was not filed within a reasonable time after
exhaustion of local remedies;
v.
Find that the Applicant alleges that his various lawyers wasted his time;
vi.
Find that the Respondent State did not in any way encumber the
Applicant’s right to a fair trial;
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