c) Simultaneously order the Respondent to abandon plans to hold a referendum on 17 or 18 December 201 5 to amend Article 101 of its Constitution in light of the Article 23(5) prohibition of the Charter on Democracy. d) Declare that even if, but without conceding that Kayumba Nyamwasa and Safari Stanley for the reasons alleged in the Res ponse have no right to seek remedy, other Applicants have this right and the Respondent by not referring to them anywhere in the Response does admit that the case is adm issible in respect to these other Applicants. e) Order the Respondent to produce the Gacaca and Military Court judgments severally referred to in the Response to enable Kayumba Nyamwasa and Safari Stanely study them and make further representations with their rights. f) Order the Respondent to delete paragraph 31 of the Response threatening the Court against deciding against the Respondent and take necessary measures against the Respondent. g) Award costs of this Application to the Applicants. h) Make such orders and reliefs as it deems necessary." (b) Respondent's Prayers 28. In its Response to the Application , the Respondent prays the Court to: a) "Declare that the Application is frivolous , vexatious , tendentious , politically motivated, an abuse of the process of the Court and an attempt to compromise the integrity of the Honourable Court b) Dismiss the Application without the necessity of summoning the respondents to the hearing in accordance with Rule 38 of the Rules of procedure c) Declare that criminal convicts still eluding justice cannot have locus standi before the Honourable Court d) Declare that the Court has no jurisdiction to hear and deal with the Application on grounds that it is defective and bad in law. !(f6