ECOWAS Community Court of Justice - 2024

30 judgments
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30 judgments
Citation
Judgment date
December 2024
Court finds State liable for torture in custody, awards N5,000,000 and orders investigation and prosecution.
Human rights – Jurisdiction of ECOWAS Court over individual claims; statute of limitations inapplicable to individual human rights actions; torture in custody – elements and burden of proof; presumption and evidentiary weight of injuries occurring in State custody; State obligation to investigate and prosecute; reparations and compensation.
3 December 2024
Default judgment: media-trial claims dismissed; prolonged interdiction violated the Applicant's right to work; US$10,000 awarded.
Human rights—jurisdiction and admissibility of default judgment; media trials and State attribution; presumption of innocence; lawfulness of interdiction pending investigation; right to work and reparations for prolonged employment deprivation.
3 December 2024
November 2024
Court grants default judgment, finds re-arrest and detention after charge withdrawal arbitrary, awards USD 10,000 damages.
* ECOWAS Court jurisdiction – human rights violations under A/SP.1/01/05; * Default judgment – requirements of notice, admissibility, formalities and well-foundedness; * Right to liberty (Article 6 African Charter) – lawfulness, reasonable suspicion, 48-hour presentation rule; * Arbitrary re-arrest and detention – failure to inform detainee of reasons; * Fair hearing, freedom of movement, equality/non-discrimination – burden of specific proof; * Reparations – monetary compensation for arbitrary detention/deprivation of liberty.
22 November 2024
22 November 2024
22 November 2024
Default judgment denied where allegations of torture lacked sufficient identity verification and probative evidence.
Human rights — Allegation of torture and ill-treatment by State security agents; default judgment — jurisdiction, admissibility and procedural formalities satisfied but insufficient evidence (identity verification and unclear injury photos) precluded grant of default judgment.
14 November 2024
Maintenance and enforcement of loitering laws violate non-discrimination, equality and freedom of movement under the African Charter.
* Human rights – Vagrancy/Loitering laws – Criminalising status vs conduct – Discriminatory impact on poor and vulnerable groups. * African Charter – Articles 2 and 3(1) – Equality and non-discrimination – Status-based criminalisation constitutes unequal application of the law. * African Charter – Article 12(1) – Freedom of movement – Vagueness, lack of legality, disproportionality and unnecessary restrictions. * Article 1 obligation – Duty to amend or repeal domestic laws incompatible with Charter rights. * Admissibility – NGO standing in public interest actions; no requirement to exhaust local remedies before this Court.
7 November 2024
ECOWAS Court finds jurisdiction over continuing human-rights abuses in detention, dismisses limitation and appellate objections, but strikes off NGOs for lack of standing.
Human rights jurisdiction – Article 9(4) – Continuing violations in detention; Limitation period – Article 9(3) not applicable to human-rights actions; Admissibility – distinction between assessing national judicial processes for rights-compatibility and exercising appellate review; Standing – NGOs lacking authorization or public-interest basis struck off.
7 November 2024
October 2024
Court dismisses case for lack of temporal jurisdiction despite rejecting limitation defence; investigation duty ancillary to substantive violation.
* Human-rights jurisdiction – ratione temporis – non-retroactivity of Protocol; critical date 19 January 2005. * Limitations – Article 9(3) Supplementary Protocol – not applicable to human-rights enforcement (no statute-bar for human-rights claims). * Obligation to investigate/prosecute – ancillary to substantive right; cannot be adjudicated absent finding of substantive violation. * Continuing violations doctrine – cannot extend Court’s temporal jurisdiction where substantive acts predate mandate.
17 October 2024
Default judgment: State violated two applicants' right to security of person; awarded damages and ordered investigation.
Human-rights jurisdiction; admissibility of direct vs. successor-in-title claims; default judgment for non-appearance; excessive use of force — violation of right to security of person; State duty to investigate and prosecute; compensation awarded.
14 October 2024
September 2024
25 September 2024
July 2024
Court lacked jurisdiction over extraterritorial disappearance claims but found a violation of the right to information and ordered disclosure.
Human rights jurisdiction – territorial limits of Article 9(4) – extraterritorial obligations and effective control; admissibility – indirect victim status and representative capacity; right to information – state duty to disclose public records and limits of confidentiality; remedies – disclosure as adequate reparation.
12 July 2024
10 July 2024
Court dismisses fair-trial and property claims for lack of evidence and absence of applicant's ownership.
* Human rights — Jurisdiction and admissibility of applications under ECOWAS human-rights competence; * Fair trial — public hearing, equality of arms and discretion of administrative courts to rely on written procedure; * Impartiality — requirement of clear, unequivocal evidence to establish judicial bias; * Legal certainty — effect of revision remedies after judicial-organisational reform; * Property rights — distinction between allocation letter (use/right) and ownership by final concession.
10 July 2024
Procedural breaches in disciplinary process rendered summary dismissal unlawful; appeal suspends all sanctions including salary cessation.
• Administrative Law / Employment – ECOWAS Staff Regulations – disciplinary procedure – Article 69 – requirement to communicate specific allegations and provide adequate time and documents for defence. • Employment Law – Summary dismissal – third-degree offences may warrant summary dismissal but must follow adversarial/due process safeguards. • Appeals – Article 73(b) – invocation of appeal suspends all sanctions, including cessation of salary, pending Council determination. • Remedies – reinstatement generally declined where relationship broken; monetary compensation and arrears appropriate where dismissal unlawful.
10 July 2024
Court found disproportionate use of force, torture and denial of effective investigation and remedy; awarded compensation and ordered fresh probe.
Human rights – Assembly and protests – Use of force by security forces – proportionality and necessity of force – Duty to investigate and provide effective remedy – Admissibility of amicus curiae intervention (Amnesty International).
10 July 2024
Application alleging human-rights violations from gas flaring dismissed for lack of evidence and causation.
• Environmental human-rights claims – gas flaring – alleged violations of ACHPR Articles 1, 4, 5, 16, 24.• Jurisdiction – mere prima facie allegation of human-rights violation triggers Community Court competence.• Admissibility – NGOs may bring actio popularis where rights are public, reliefs benefit the public and victims are envisagable.• Burden of proof – applicant must prove actual harm and causal link to State acts/omissions.• Evidence – unchallenged independent reports and domestic reforms relevant to merits and reparation.
4 July 2024
June 2024
Application succeeds on fair-trial non-retroactivity ground; equality and right-to-work claims dismissed.
* Jurisdiction – Court’s competency under Article 9(4) of the Protocol – admissibility under Article 10(d). * Human rights – administrative/disciplinary proceedings – fair hearing – prohibition of retroactive criminalisation (Article 7(2) African Charter). * Equality – equal protection – burden of proof for unjustified differential treatment; insufficient evidence to show discrimination. * Right to work – requirement to prove causal link between state measures and dismissal. * Remedies – expungement of unlawful disciplinary measures; award of general damages.
6 June 2024
Application dismissed as inadmissible for lack of proof of parentage and thus lack of locus standi.
Human rights — Admissibility — Locus standi — Victim status (direct/indirect) — Requirement to prove family relationship by clear prima facie evidence — Court’s jurisdiction under Article 9(4) of the Protocol — Costs: parties bear own costs where defendant did not claim costs.
6 June 2024
Court found jurisdiction but dismissed the NGOs’ property claim for lack of locus standi; costs awarded to respondent.
* Jurisdiction – Article 9(4) Supplementary Protocol – mere allegation of human rights violation suffices to confer prima facie jurisdiction. * Admissibility – victim status (locus standi), non-anonymity, non-pendency required for human-rights claims. * Property rights – ownership/legitimate expectation must be established to claim violation under Article 14 ACHPR. * Bank–customer disputes may be tortious and fall outside human-rights competence if applicant lacks victim status.
6 June 2024
Delay in signing land deeds did not violate Article 14 where tribal certificates gave no title and state attribution for vandalisation was not proven.
Human rights jurisdiction – property rights (Article 14 African Charter) – corporate applicant's standing; Public Lands Law – Tribal Land Certificate as consent only; Title vests upon completion of statutory formalities and presidential signature; State responsibility – attribution and positive obligations to protect property; Admissibility – capacity and board resolution evidence.
6 June 2024
Court competent to interpret its judgments but refused application as inadmissible and cannot order national enforcement.
* ECOWAS Court – interpretation of judgments – Article 23 Protocol A/P.1/7/91 – competence to interpret when meaning or scope is in doubt. * Admissibility – interpretation applications must identify specific operative provisions, words or passages and aim to facilitate execution, not re‑litigation. * Enforcement – ECOWAS Court cannot order municipal courts to enforce its decisions; enforcement is for Member States/national competent authorities (2005 Additional Protocol, Article 24). * Procedure – expedited procedure requires demonstrated urgency; default judgment triggers Court's duty to verify jurisdiction and admissibility.
6 June 2024
The Court lacks jurisdiction to directly enforce its judgments; enforcement follows national procedure and Commission sanctions mechanisms.
* Public international/ECOWAS Court jurisdiction – competence to enforce own judgments – Court lacks jurisdiction to order direct enforcement against Member States. * Procedural law – Enforcement of Community Court judgments – writ of execution issued by Chief Registrar; execution by competent national authority under domestic rules (Article 24, Supplementary Protocol). * Locus standi – Individual applicants lack standing to seek community sanctions; President of the Commission vested with enforcement/sanctions prerogatives (Supplementary Act on Sanctions). * Interaction with domestic proceedings – domestic criminal processes and national enforcement rules govern execution of Community Court writs.
6 June 2024
Domestic military immunity and non-exhaustion of local remedies do not bar ECOWAS Court jurisdiction over alleged rights violations.
Human rights – Right to life – Alleged extrajudicial killing by military – Domestic military immunity (Armed Forces Act Section 239) cannot oust international obligations – ECOWAS Court jurisdiction under Article 9(4) of Protocol – Non-exhaustion of local remedies not required.
6 June 2024
May 2024
ECOWAS Court lacked temporal jurisdiction for some killings and dismissed the NGO’s case for lack of standing.
• Jurisdiction (ratione temporis) – non-retroactivity of treaties – Protocol A/SP.1/01/05 – distinction between instantaneous and continuous violations. • Admissibility – Article 10(d) of the 2005 Additional Protocol – victim status and locus standi for NGOs. • Actio popularis and representative actions – requirements for NGO registration, mandate/authorization, and public-interest litigation. • Obligation to investigate and prosecute – scope depends on Court’s ratione temporis jurisdiction.
30 May 2024
Revision refused: application inadmissible because applicants’ ignorance of the alleged new facts resulted from their negligence.
Administrative law – Revision of judgment – Article 25 Protocol and Articles 92–94 Rules – Requirements for revision: timeliness, new fact, ignorance not due to negligence, decisiveness – Duty to disclose by former staff – Admissibility test cumulative.
30 May 2024
ECOWAS Court finds State violated a company’s property and timely‑decision rights; awards CFA 40,000,000 and costs.
• International law – Jurisdiction of ECOWAS Court – Signature/provisional entry into force of Protocol A/SP.1/01/05 binds a State despite domestic non‑ratification objections. • Admissibility – Legal persons may sue for violations of fundamental rights (property); shareholder claims for reflective losses are inadmissible absent distinct personal rights. • State responsibility – Acts of state agents and organs attributable to the State; non‑state actors not proper parties before Court. • Human rights – Article 14 African Charter (right to property) and Article 7(1)(d) (reasonable time) – annulment of permits violated property and reasonable‑time rights. • Remedies – Award of fair compensation and costs to successful applicant.
29 May 2024
February 2024
State liable for police shooting of protester—violations of security, torture and failure to provide effective remedy.
Jurisdiction and admissibility of human rights applications; State responsibility for police use of force; Right to security of the person (African Charter Article 6 / ICCPR Article 9); Definition and threshold for torture (African Charter Article 5 / ICCPR Article 7 / CAT Article 1); Duty to investigate, prosecute and provide effective remedies; Reparations including compensation and institutional measures to prevent recurrence.
28 February 2024
January 2024
Court finds violations of Articles 5, 16 and 6 of the African Charter for detention and denial of health; 2004–2005 claims inadmissible.
• Human rights – jurisdiction ratione temporis – non‑retroactivity of Protocol extending Court's human‑rights mandate (no jurisdiction for 2004–2005). • Prohibition of torture – Article 5 African Charter – inhuman detention conditions and denial of minimum guarantees can prove torture absent full medical reports. • Right to health – Article 16 African Charter – denial of specialized care for detainee. • Liberty and security – Article 6 African Charter – procedural defects, secret detention and failure to inform reasons violate liberty safeguards. • Presumption of innocence – Article 7 African Charter – not established where no evidence of extrajudicial portrayal of guilt.
30 January 2024
Court lacked jurisdiction: claim time-barred under Article 9(3) and human-rights claims against ECOWAS Institution are impermissible.
• Jurisdiction – Article 9(3) Supplementary Protocol – three-year limitation for actions against Community institutions – effect of delay and continuing-violation exception. • Human-rights claims – only States, not Community institutions, are proper defendants for domestic constitutional/human-rights violations before the Court. • Procedural – failure to sue appropriate party and duplicative parties – suomoto dismissal of redundant defendant. • Employment law – summary dismissal and alleged denial of fair hearing considered but not entertained due to lack of jurisdiction/time bar.
30 January 2024