4. The Applicants allege that the campaign for the amendment of Article 101 of the Constitution has been co nducted against a climate of fear and that any cha llenges to the amendments of the Constitution would likely not succeed as the judicia ry of Rwanda is allegedly not independent, particularly since some judicial officers are also members of the Respondent's Ruling Party. 5. The Applicants further allege that this has been against a backdrop of arbitrary arrest, detentions and trials of leading political figures such as Victoire lngabire Umuhoza , the former President, Pasteur Bizimungu, the former Minister, Charles Ntakiruntika and Bernard Ntaganda. One of the Applicants, General Kayumba Nyamwasa, states that South African Courts have found that his attempted assassination was conducted by persons linked to the Respondent. The Applicants also allege that another military officer, Lieutenant Colonel Seveline Ngabo has been held incommunicado in an unknown location since 20 August 20 10 and that despite the East African Court of Justice finding that his detention was unlawful, he has neither been presented in Court nor charged with any offence. 6. The Applicants also claim that the filing of an application by the Green Party in the courts in Rwanda to challenge the amendment of Article 101 of the Constitution, is a sham since this Party is a creation of the President and the whole exercise is intended to lend legitimacy to the process of the amendment of the Constitution by allowing these constitutional challenges. 7. The Applicants have filed affidavits in support of the Application. The affidavit by Safari Stanley states that loca l remed ies in Rwanda are neither practical nor effective since the President of the Republic of Rwanda dictates how courts should decide matters before them. They add that, since the President has a personal interest in the matter, the outcome of any action at the loca l level would be to allow the amendment. ff 8. The Applicants base their Application on Articles 13 (freedom to participate in government), 19 (equality of peoples), 21 (freedom of peoples to dispose of their b-- ~ --/ ~3 ~ (.!:1/ C!!:-

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