article 66(2)(c) of the Revised ECOWAS Treaty was read together with the freedom of expression provision in article 9 of the Charter in Zongo. An application can be based on provisions of the Universal Declaration of Human Rights as there are corresponding provisions in the African Charter and other human rights treaties (Frank David Omary and others v The United Republic of Tanzania, application 001/2012, ruling, 28 March 2014, paras 73 and 76)

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