African Commission on Human and Peoples Rights - 2024 March

2 judgments
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2 judgments
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Judgment date
March 2024
State found guilty of torture, arbitrary detention and denial of fair‑trial rights; ordered investigation, reparations and safeguards.
* Admissibility – exhaustion of local remedies – practical unavailability due to severe injury, fear and financial incapacity. * Torture and ill‑treatment – Article 5 – acts meeting UNCAT/Commission threshold (physical and psychological torture). * Arbitrary arrest and detention – Article 6 – prolonged incommunicado detention without charge or prompt judicial review. * Fair trial rights – Article 7 – right of access to counsel, habeas corpus and prompt appearance before judicial authority. * State obligations – Article 1 – duty to investigate, prosecute, provide reparations and prevent repetition; remedies ordered (investigation, prosecution, compensation, apology, safeguards, training).
8 March 2024
Respondent failed due diligence: ineffective investigation, unlawful detention, and discriminatory treatment of a trafficking victim.
• Human rights – Trafficking in persons – State due‑diligence to prevent, investigate and prosecute private perpetrators – effective investigation standards. • Cruel, inhuman or degrading treatment – Article 5 African Charter – sexual violence and trafficking. • Discrimination – Articles 2 and 18(3) African Charter and Article 2 Maputo Protocol – substantive equality and multiple discrimination (sex, age, nationality). • Admissibility – Article 56 exhaustion exception where domestic remedies ineffective; timeliness and victim capacity considerations. • Remedies – obligation to investigate/prosecute, legislative reform, reparations and domestic quantum determination.
8 March 2024