plaintiff suffered the following violation and infringements of her common law rights and without derogating from the generality thereof, her common law and personality rights and more particularly 6.1 will be unable to bear children in future and found a family; 6.2 lost marriage prospects; 6.3 suffered and continues to suffer ongoing mental and emotional anguish; 6.4 endured and continues to endure shock, pain and suffering; 4 6.5 suffered and continues to suffer infringement of her rights to bodily and psychological integrity; 6.6 was subjected to torture or to cruel and inhuman or degrading treatment or punishment; 6.7 suffered and continues to suffer a violation of her dignity. 7. Alternatively to paragraph 6 supra, and as a further consequence of the aforesaid wrongful and unlawful conduct by defendant’s aforementioned employees as set out in paragraph 3, alternatively 4 supra, plaintiff suffered a violation and an infringement of her rights guaranteed and protected under the Namibia Constitution, particularly: 7.1 Her right to life in terms of Article 6 of the Constitution; 7.2 Her right to liberty in terms of Article 7 of the Constitution; 7.3 Her right to human dignity in terms of Article 8 of the Constitutions; 7.4 Her right to found a family in terms of Article 14 of the Constitution. 8. As a result of the facts and circumstances as set out in paragraph 6 supra, alternatively paragraph 7 above, plaintiff suffered loss or damages (both past and contingent) in the amount of N$1 million. It is not reasonable nor practical to apportion the aforementioned globular amount of N$1 million to any of the numerous and particular infringements, violations and invasions of plaintiff’s rights suffered by her as referred to in paragraph 6 and 7 above. 9. In as much as the aforesaid claim for loss or damages is based on what is set out in paragraph 7 above, plaintiff claims such loss or damages as monetary compensation in terms of Articles 25 (3) and 25 (4) of the Namibian Constitution. CLAIM 2 10. The aforesaid sterilisation of the plaintiff by the defendant’s aforementioned employees was a consequence of her being a woman who is HIV-positive. 11. As a result, the aforesaid sterilisation was a wrongful and unlawful practice of impermissible discrimination against the plaintiff. 5