African Court on Human and Peoples Rights - 2022

59 judgments
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59 judgments
Citation
Judgment date
December 2022
Court finds prima facie jurisdiction but dismisses or rejects provisional measures as moot, non‑justiciable against non‑party organ, or unfounded.
* Provisional measures – prima facie jurisdiction – Court may entertain urgent requests though full jurisdiction on merits not yet established. * Provisional measures – mootness – measures aimed at preventing events that already occurred are dismissed as moot. * Provisional measures – non‑party organs – Court cannot order provisional measures against the African Union Executive Council which is not a party. * Provisional measures – detention warrants – suspension request refused where detention rests on conviction after trial. * Provisional measures – Court will not determine composition of AU organs or amend parties’ identities in provisional relief.
21 December 2022
Applicant failed to show a sufficient link between alleged rights violations and the scheduled elections; provisional suspension refused.
Provisional measures — prima facie jurisdiction — extreme gravity, urgency and irreparable harm — necessity of causal link between requested interim relief and merits — refusal to suspend scheduled elections where no sufficient connection established.
16 December 2022
Court dismisses requests to suspend elections, annul future parliamentary acts and to order a presidential medical exam as premature or unsupported.
• Provisional measures – prima facie jurisdiction – Applicant’s rights under the African Charter – standard of extreme gravity, urgency and irreparable harm; • Provisional measures not to decide merits – connection between requested interim relief and rights alleged; • Requests to suspend elections or annul future parliamentary acts premature; • Court will not order medical examination of head of State absent evidence.
16 December 2022
Application declared inadmissible for failure to exhaust a newly available domestic remedy to contest arbitral awards.
Labour law; access to justice; exhaustion of domestic remedies; enforceability of arbitral awards; competence and admissibility of petitions before the African Court.
1 December 2022
Application declared inadmissible for failure to exhaust newly available domestic remedies (amendment to Article L.229).
* Human rights procedure – Admissibility – Exhaustion of local remedies – domestic amendment creating remedy (Law No. 021-2017 amending Article L.229) renders application inadmissible if not pursued.* Labour law – Enforcement and annulment of Arbitration Council awards in collective disputes – availability of appeal to Supreme Court’s Social Chamber.* Jurisdiction – African Court’s material, personal, temporal and territorial jurisdiction affirmed.
1 December 2022
Application alleging unlawful detention and prosecutorial overreach declared inadmissible for failure to exhaust domestic remedies.
Jurisdiction of African Court; admissibility—exhaustion of local remedies; premature filing during ongoing domestic criminal proceedings; prosecutorial detention orders under domestic law; bail procedures; costs—each party bears own costs.
1 December 2022
Review application dismissed for lack of new facts; Court retains jurisdiction despite State's withdrawal.
* Review procedure (Article 28(3) Protocol; Rule 78 Rules of Court) – review limited to genuinely new facts or evidence unknown at time of judgment * Personal jurisdiction – withdrawal of Article 34(6) Declaration does not affect pending cases or review proceedings arising from judgments in such cases * Admissibility – new fact must pre-exist judgment and be unknown despite due diligence; appellate re-litigation not permitted * Exhaustion of local remedies – finding that domestic remedies existed is part of prior judgment and not a new fact * Reparations – reassessment requests comparing awards in other cases do not constitute new facts
1 December 2022
Court found no violation of fair-trial or non-discrimination rights, but reiterated that mandatory death penalty violates the Charter.
• Jurisdiction – withdrawal of Article 34(6) Declaration not retroactive; continuing detention on death row gives temporal jurisdiction. • Admissibility – exhaustion of ordinary judicial remedies; filing within reasonable time considering incarceration and lack of awareness. • Fair trial – evaluation of identification evidence and national courts’ margin of appreciation. • Non-discrimination – burden on applicant to prove discriminatory treatment; absence of evidence. • Death penalty – Court reiterates mandatory death penalty violates the Charter and requires discretionary sentencing procedures.
1 December 2022
Court had jurisdiction and found local remedies exhausted but declared application inadmissible for unreasonable delay.
• Jurisdiction – material jurisdiction to examine alleged violations of the African Charter arising from domestic criminal proceedings; not an appellate court but may assess compliance with international human rights standards. • Jurisdiction – temporal, personal and territorial jurisdiction satisfied where domestic judgments post‑date ratification and Declaration remains applicable to pending cases. • Admissibility – exhaustion of local remedies satisfied by appeal to the Court of Appeal; extraordinary review not mandatory. • Admissibility – applications must be filed within a reasonable time; excessive delay (over seven years) renders application inadmissible. • Procedural – admissibility requirements are cumulative; failure of one (reasonable time) suffices to dismiss application.
1 December 2022
Mandatory death sentence violates right to life; undue pre-trial delay and death-row detention violate fair trial and dignity rights.
* Jurisdiction – material, personal, temporal, territorial – Court empowered to assess domestic proceedings against Charter obligations * Admissibility – exhaustion of local remedies (appeal to Court of Appeal sufficient); reasonable time for filing assessed in light of incarceration and pending review * Criminal law – Mandatory death penalty – denial of judicial discretion – violation of Article 4 (right to life) * Fair trial – undue delay – six-plus years pre-trial – violation of Article 7(1)(d) * Right to defence – allegations of ineffective counsel and conflict of interest dismissed for lack of substantiation * Human dignity – death-row phenomenon and prolonged pre-trial detention constitute inhuman or degrading treatment under Article 5 * Reparations – moral damages; repeal mandatory death sentence; resentencing/rehearing; publication and reporting orders
1 December 2022
Application challenging exclusion of pregnant schoolgirls held inadmissible as matter already decided by ACERWC; Court retained jurisdiction.
Human rights — Education and non-discrimination — Exclusion of pregnant and parenting girls from public schools — Admissibility — Article 56(7) Charter — Settlement by another regional organ (ACERWC) — Three-part test: identity of parties, similarity of subject-matter, prior decision on merits — Jurisdiction retained — Provisional measures moot.
1 December 2022
Mandatory death penalty and hanging violated rights to life and dignity; unreasonable pre-trial delay breached fair-trial rights.
Jurisdiction and admissibility; reasonableness of filing time after exhaustion of local remedies; mandatory death penalty arbitrary under Article 4; hanging and death-row detention violate Article 5; unreasonable pre-trial delay violates Article 7(1)(d); no breach as to presumption of innocence or effective counsel; remedial orders include repeal of mandatory death penalty, sentencing rehearing and moral damages.
1 December 2022
Court finds Benin violated judicial independence, free expression and failed to execute prior judgments; orders institutional reforms and damages.
• Jurisdiction – withdrawal of Article 34(6) Declaration has no retroactive effect; Court retains jurisdiction over applications filed before withdrawal took effect. • Admissibility – exhaustion of local remedies required; legislative challenges ruled admissible after domestic Constitutional Court review; administrative memorandum claims inadmissible for non-exhaustion. • Human rights – judicial independence (Article 26 Charter) violated by executive-dominated HJC composition. • Freedom of expression – Article 410(3) Penal Code unlawfully restricts permissible criticism of judicial decisions (Article 9(2) Charter; Article 19 ICCPR). • Compliance – State violated Article 30 of the Protocol by non-execution of Court decisions. • Remedies – declaratory relief, legislative reform orders, publication and reporting, moral damages awarded.
1 December 2022
September 2022
Application dismissed as inadmissible for failure to exhaust domestic remedies despite Respondent's default.
* Human rights – Fair trial rights – Allegations including denial of adversarial proceedings, equality of arms, right to reasons and effective remedy – Requirement to exhaust domestic remedies before approaching the African Court. * Procedure – Default judgment – Court may enter judgment in default where a State fails to respond, but admissibility requirements remain to be satisfied. * Admissibility – Article 56(5) Charter/Rule 50(2)(e) – Pending cassation appeal not shown to be unduly prolonged; application therefore premature and inadmissible.
22 September 2022
Court found presidential decrees breached rights to be heard and political participation; ordered repeal and Constitutional Court operationalisation.
• International and regional jurisdiction – State consent to Court jurisdiction via ratification and Article 34(6) declaration; • Admissibility – exhaustion of local remedies inapplicable where Constitutional Court (exclusive forum for constitutional review) is not operational; • Constitutional law – legality and procedural requirements for emergency measures; • Human rights – violations of right to be heard (Article 7(1)(a)), political participation (Article 13(1)) and State obligation to give effect to Charter rights (Article 1); • Remedies – repeal of decrees, operationalisation of Constitutional Court, reporting and guarantees of non-repetition.
22 September 2022
Application inadmissible for failure to exhaust available cassation remedy; Court confirms jurisdiction and orders each party to bear own costs.
* Human rights – Admissibility – Exhaustion of local remedies – Availability and effectiveness of cassation remedy – Failure to exhaust leads to inadmissibility. * Jurisdiction – State deposited Article 34(6) declaration; Court competent to interpret Charter and ICCPR. * Enforcement of domestic judgments – provisional enforcement and recourse to ordinary remedies.
22 September 2022
Application declared inadmissible for failure to exhaust cassation remedy despite Court’s jurisdiction.
• Human rights – fair trial (Article 7 African Charter) – alleged violations of right to fair trial, equality of arms and adversarial principle. • Admissibility – exhaustion of local remedies – requirement to lodge cassation appeal – effectiveness and availability of cassation remedy. • Jurisdiction – material, personal, temporal and territorial jurisdiction of the African Court. • Remedies – limits on Court’s power regarding pardon, commutation and parole when domestic remedies not exhausted.
22 September 2022
Application declared inadmissible for unreasonable delay despite exhaustion of local remedies; Court affirms jurisdiction.
• Jurisdiction – Material jurisdiction to examine alleged Charter violations arising from national criminal proceedings without acting as appellate court • Jurisdiction – Temporal jurisdiction where domestic judgments post-dated ratification and alleged effects are continuing • Admissibility – Exhaustion of local remedies satisfied where applicant’s appeal to highest domestic court was determined • Admissibility – Reasonable time requirement under Article 56(6): undue delay (almost seven years) renders application inadmissible • Costs – Each party to bear its own costs
22 September 2022
Failure to inform an indigent accused of bail or provide free counsel violates fair-trial rights; limited moral compensation awarded.
• Jurisdiction – African Court competent to assess compliance of domestic criminal proceedings with Charter standards without acting as appellate court. • Admissibility – Reasonable-time test; incarceration, indigence and lack of access to records may justify delay. • Fair trial – Right to liberty includes right to apply for bail and to be informed of that right, especially if unrepresented. • Right to defence – Indigent accused facing serious offences must be provided free legal assistance at trial and on appeal. • Remedies – Moral damages awarded for established fair-trial violations; restitution (release) refused absent miscarriage of justice.
22 September 2022
Applicants’ political-monitoring and security rights violated; formal collation-sheet authentication breaches found, but election not annulled.
Human rights – Electoral rights – Jurisdiction and admissibility – Exhaustion of domestic remedies – Independence and reasoning of constitutional courts – Right to monitor elections and transparency of collation sheets (hologram/sticker) – Protection of candidates (security of the person) – Reparations for procedural and moral prejudice.
22 September 2022
Court has jurisdiction but declares application inadmissible for failure to exhaust local remedies.
Human rights – Fair trial rights (presumption of innocence, right to defence, impartial tribunal) – Judicial independence – Jurisdiction of the African Court to assess compliance of domestic proceedings with the Charter – Admissibility – Requirement to exhaust local remedies – Applications based on same facts previously declared inadmissible for non‑exhaustion.
22 September 2022
Application inadmissible: Court had jurisdiction and exhaustion was met, but filing exceeded a reasonable time and was dismissed.
Human rights – jurisdiction of African Court – material jurisdiction to assess conformity of domestic criminal proceedings with the Charter; Temporal jurisdiction – continuing violations and non-retroactivity of obligations; Personal jurisdiction – effect of withdrawal of Article 34(6) Declaration; Admissibility – exhaustion of local remedies by appeals to highest domestic courts; Admissibility – filing within a reasonable time; Costs – each party bears own costs.
22 September 2022
Applicant’s procedural complaints did not establish violation of the right to have one’s cause heard; application dismissed.
* Jurisdiction – material, personal, temporal and territorial – withdrawal of Article 34(6) declaration has no retroactive effect on pending cases. * Admissibility – exhaustion of local remedies; reasonable time. * Fair trial – Article 7(1) – issues of conviction before sentence; unsworn child evidence; admissibility of exhibits; court assistance for defence witnesses. * Reparations – dismissed where no violation established. * Costs – each party to bear own costs.
22 September 2022
Application dismissed as inadmissible for unreasonable delay in filing after exhaustion of domestic remedies.
Human rights – Access to the African Court – Jurisdiction established where Declaration deposited when application filed – Withdrawal of Declaration has no retroactive effect on pending cases; Admissibility – Requirement to exhaust local remedies satisfied; Temporal admissibility – application filed six years after exhaustion held not filed within a reasonable time and therefore inadmissible; Default – Respondent’s failure to file response allows Court to proceed suo motu.
22 September 2022
Court found no breach by Respondent States of Sahrawi self‑determination obligations; AU Assembly admission decision not imputable to States.
• Human rights – Peoples’ right to self‑determination (Article 20 African Charter) – Nature as erga omnes/jus cogens – Extraterritorial obligations and assistance to colonised peoples. • Jurisdiction – Material, personal, temporal and territorial jurisdiction of the African Court in cases concerning extraterritorial effects of State omissions. • Admissibility – actio popularis/public‑interest standing; exhaustion of local remedies dispensed where ineffective or unduly burdensome; requirement not to be based exclusively on media. • Separation of legal personalities – AU Assembly decisions and limits on imputing Assembly acts to individual Member States. • Remedies – reparations require a finding of State responsibility and causal link.
22 September 2022
Applicant’s challenge to retrenchment dismissed; domestic retrenchment and litigation found compliant with Charter standards.
Labour law – retrenchment during institutional transition – right to work (Article 15) – fairness of domestic retrenchment procedures; Human rights – fair trial (Article 7) – impartiality, length of proceedings, consideration of evidence; Equality and non‑discrimination (Articles 3 and 2) – status distinctions between Ministry employees and commissioners; Admissibility – exhaustion of local remedies and filing within reasonable time; Jurisdiction – scope of African Court vis‑à‑vis domestic final rulings.
22 September 2022
Applicant’s case dismissed as inadmissible for failure to exhaust cassation remedy before filing at the African Court.
* Human-rights jurisdiction – review of domestic criminal proceedings for compliance with Charter and other instruments – not an appellate function. * Admissibility – exhaustion of local remedies – cassation appeal before Supreme Court effective; premature filing. * Provisional measures – rendered moot where main application inadmissible. * Costs – each party to bear its own costs.
22 September 2022
Application inadmissible for failure to exhaust the available domestic civil appeal remedy.
• Human rights — Property rights (Article 14 African Charter) — Alleged deprivation by domestic civil judgment. • Admissibility — Exhaustion of local remedies — Requirement to pursue ordinary civil appeal. • Civil procedure — Adversarial judgment and legal representation — effect on appeal time-limit and applicant's obligations. • Criminal provision (Article 410) — Not a bar to exercising statutory remedies. • Jurisdiction — Court competent despite State's subsequent withdrawal of Article 34(6) Declaration for pending cases.
22 September 2022
Application dismissed as inadmissible for failure to exhaust available domestic remedies; Court affirms jurisdiction.
• Human rights procedure – admissibility – exhaustion of local remedies – ordinary, available and effective remedies must be exhausted before seising the Court; • Labour law – alleged non-payment of retrenchment entitlements – domestic labour remedies and appeals (appeal and cassation) required; • Admissibility – principle of anteriority: exhaustion assessed as at date of filing; • Jurisdiction – Court has personal, material, temporal and territorial jurisdiction.
22 September 2022
Failure to prove filing of a cassation appeal led to inadmissibility for non-exhaustion of local remedies despite Court's jurisdiction.
* Jurisdiction – Material jurisdiction to hear alleged violations of Articles 7(1)(a) and 7(1)(d) of the African Charter – Court not an appellate domestic court but may assess compliance with Charter standards. * Admissibility – Exhaustion of local remedies – Requirement to lodge cassation appeal and prove filing by registry attestation. * Failure to prove cassation appeal – Non-exhaustion renders application inadmissible. * Costs – Each party bears its own costs.
22 September 2022
Application struck out after applicant discontinued proceedings; Court relied on Rule 65(1)(a).
Procedure – Discontinuance and striking out – Application may be struck from cause list where applicant notifies intention not to proceed (Rule 65(1)(a)); right to seek restoration under Rule 65(3).
22 September 2022
August 2022
Court orders access to medical care and CNHU medical file; dismisses other provisional measures for lack of urgency or evidence.
Provisional measures – prima facie jurisdiction after State withdrawal of Article 34(6) Declaration – criteria of extreme gravity, urgency and irreparable harm – right of access to health care and medical records – limits on provisional relief regarding third parties, evidentiary production and allegations lacking supporting evidence.
15 August 2022
July 2022
Applicants granted leave to amend pleadings before close of pleadings due to new legal representation and interests of justice.
* Procedure – Pleadings – Amendment of pleadings under Rule 47 – Request made before close of pleadings; requirement to specify parts and reasons; interests of justice where applicants change from self-representation to counsel – leave to amend granted.
28 July 2022
June 2022
Application struck out for failure to pursue proceedings and non-compliance with court requests under Rule 65.
Rule 65(1)(b) – striking out applications for failure to pursue – party diligence and compliance with Registry requests; proofs of delivery and attribution of non-compliance to lack of diligence; discretionary strike out to preserve court resources; strike out without prejudice to re-filing under Rule 65(3).
23 June 2022
Application struck out for failure to pursue proceedings and comply with Court requests under Rule 65.
Procedure — Striking out under Rule 65(1) for failure to pursue proceedings; party diligence; requests for supporting documents and Reply; proof of delivery negating non-receipt; striking out without prejudice to re-filing under Rule 65(3).
23 June 2022
Court orders Kenya to restitute Ogiek land, recognize them as indigenous, and pay material and moral reparations.
Indigenous peoples – reparations – temporal scope of state responsibility – quantification of collective material and moral prejudice – delimitation, demarcation and collective titling of ancestral lands – recognition and consultation (FPIC) – establishment of development fund – implementation and reporting.
23 June 2022
Court joins decision on provisional measures to the merits where requested measures mirror substantive relief and could prejudice the merits.
Procedure — recusal of national judge — provisional measures — requested measures mirror substantive relief — Court joins decision on provisional measures to merits; failure of State to respond.
23 June 2022
Court has jurisdiction to examine Charter breaches in judicial acts but dismissed the case for failure to exhaust local remedies.
Jurisdiction – material jurisdiction to assess whether national judicial decisions comply with the African Charter; Admissibility – requirement to exhaust effective local remedies before filing; Non-exhaustion – application premature where appeal pending; Judicial independence – allegations insufficient or subsequent to filing cannot excuse non-exhaustion.
23 June 2022
State’s failure to provide trial records denied appeal rights; court awarded material and moral reparations and ordered publication and reporting.
Human rights – Fair trial (Article 7(1)(a)) – Failure to provide certified trial records preventing appeal; Reparations – default judgment under Rule 63(1); Material damages – flexible assessment using minimum wage and inflation where private evidence unavailable; Moral damages – presumed upon violation and quantified on equity; Indirect victims – requirement of documentary proof of relationship; Measures of satisfaction – publication and periodic reporting; Enforcement – tax‑free awards and interest on arrears.
23 June 2022
State violated rights to equal protection, to have one’s cause heard and to an effective remedy; reparations awarded.
Human rights — Temporal jurisdiction for continuing violations; admissibility — exhaustion of domestic remedies and reasonable time; right to equality before the law and to have one’s cause heard — ouster of ordinary courts and failure to provide effective remedy; reparations — material and moral damages, implementation reporting.
23 June 2022
An application may be struck out under Rule 65 when the applicant fails to prosecute the matter diligently.
Rule 65(1) – Striking out for failure to pursue – Applicant’s diligence – Multiple extensions and non-compliance; Proof of delivery of Court notices; Discretion to strike out; Strike out without prejudice to restoration under Rule 65(3); Provisional measures (stay of execution) previously issued.
23 June 2022
Applicants’ exclusion from promotion training and Article 125’s authorisation requirement did not breach equality, education or promotion rights.
Administrative law; equality before the law – jurisprudential change; civil service law – promotion and training – prior hierarchical authorisation; compatibility of national police status law with Article 13(2) Charter, Article 25(c) ICCPR, Article 13(2)(c) and Article 7(c) ICESCR; exhaustion of local remedies; reasonableness of restrictions on access to public service.
23 June 2022
Applicant granted leave to amend pleadings; late amendments deemed filed; oral hearing deferred until respondent is served and may respond.
Amendment of pleadings – Rule 47(2) and Rule 90 – Leave to amend granted in interest of justice; late amended pleadings deemed filed; request for oral proceedings deferred pending service and reciprocal written submissions.
23 June 2022
Court exercised discretion to reopen pleadings and allow a reply, deeming the Respondent's late Response properly filed.
Procedural law — Reopening pleadings under Rule 46(3); Reply after Respondent’s Response under Rule 44(2); Court’s inherent powers under Rule 90; consideration of late-filed Response; fairness and interest of justice in procedural scheduling.
7 June 2022
May 2022
Court reopened pleadings and granted both parties 45 days to reply to new post-closure submissions under Rule 46(3).
Reopening pleadings; Rule 46(3) Rules of Court; Rule 44(2) procedural replies; Rule 90 inherent powers; post-closure submissions raising new arguments; provisional measures stayed execution; Article 34(6) Declaration withdrawal does not affect pending cases.
13 May 2022
April 2022
Proceedings reopened so State can respond where initial service of the application was doubtful.
Procedure – Service of process – Non-acknowledgement of initial notification – Rule 46(3) – Reopening pleadings in the interest of justice and to safeguard adversarial proceedings; Expropriation and unpaid court-ordered compensation.
1 April 2022
March 2022
Provisional measures denied: applicants failed to specify measures or prove extreme gravity, urgency, and irreparable harm despite prima facie jurisdiction.
• Jurisdiction – prima facie jurisdiction where application filed before withdrawal of Article 34(6) Declaration effective date; • Provisional measures – require extreme gravity, urgency and risk of irreparable harm; • Burden of proof – applicants must specify requested measures and demonstrate urgency and irreparable harm; • Freedom of expression – alleged violation arising from internet shutdown on election day.
24 March 2022
Court orders provisional measures and merits to be heard together in application alleging unconstitutional seizure of power.
Provisional measures – requests mirroring merits – risk of prejudging merits – decision to consider provisional measures and merits together – expeditious examination of application arising from alleged abrogation of constitution.
24 March 2022
Application struck out for failure to prosecute and inability to locate the applicant; restoration permitted under Rule 65(3).
Procedure – Rule 65 – Strike out for failure to prosecute; Parties’ diligence in pursuing cases; Representation – inability to obtain Power of Attorney where applicant cannot be located; Restoration of struck-out applications under Rule 65(3).
24 March 2022
Court found violations of reasonable-time, adversarial rights, effective remedy and judicial/electoral-body independence; ordered reforms and CFA1,000,000 compensation.
Electoral law; fair trial — reasonable time and adversarial principle; effective remedy and recusal procedures; judicial independence; independence and impartiality of electoral management bodies; ACDEG and ECOWAS Protocol compliance.
24 March 2022