-4 - 3.6. The restitution and payment of US$300 Million damages to the Plaintiffs as Exemplary Damages against the Defendants for the losses suffered over the violation of their rights. 3.7. The Plaintiffs and their supporters have been subjected by the Defendants to unimaginable political intimidation/exclusion, psychological trauma victimization and humiliation which affected their participation at the February 14, 2015 presidential elections, and right to compete in getting their candidates freely elected at that presidential election on equal and level playing grounds. 3.8. This Court compelling the confiscation and deposition into Court the sum of N21.27 Billion Presidential Campaign Fund as illegally accepted by and in possession of the 3rd and 4th Defendants and due sanctions thereof. 4. SUMMARY OF PLEAS IN LAWS ON WHICH APPLICATION IS BASED 4.1. The Plaintiffs are entitled and have the rights to be allowed to freely choose or have their candidate at the presidential elections to be freely chosen in accordance with the provisions of the law, devoid of any form of political intimidation, undue advantage by the ruling political party and their presidential candidate at that election. 4.2. That acts of political intimidation and usurpation of all state apparatus in favor of a sitting President and a nominated candidate at a president election is a violation of the Plaintiffs right to participate in that election on ground of equality before the laws of the land. 4.3. That acts of encouraging political intimidation and non-investigation and prosecutions of the ruling party’s presidential candidates acceptance and possession of N21.27 Billion over and above the prescribed N1 Billion in contravention of the Electoral Laws is a violation of the Plaintiffs’ right to freely contest and be freely chosen in accordance with the laws at the said presidential election. 4.4. Human Rights of citizens of member states are to be protected and enforced and are entitled to commensurate damages thereof.

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