25th Ordinary Session: Commissioner Ben-Salem
26th Ordinary Session: Commissioner Ben-Salem
27th Ordinary Session: Commissioner Ben-Salem
28th Ordinary Session: Commissioner Ben-Salem
SUMMARY OF FACTS
1. The communication, which was sent through e-mail is dated 25th May 1998,
and was received at the Secretariat on 26th May 1998
2. The Complaint is filed by Media Rights Agenda, a Nigerian Human Rights
NGO based in Lagos on behalf of Niran Malaolu, Editor of an independent
Nigerian daily Newspaper, The Diet.
3. The author complains that Mr. Niran Malaolu was arrested together with
three other staff of the Newspaper by armed soldiers at the editorial
offices of the Diet Newspaper in Lagos on December 28th, 1997.
4. Neither Niran Malaolu nor his three colleagues were informed of the
reasons for their arrest or shown a warrant of arrest.
5. The three other colleagues who were arrested along with Malaolu were
6. Niran Malaolu continued to be held without charges until 14th February
1998 when he was arraigned before a Special Military Tribunal for his
alleged involvement in a coup.
7. Throughout the period of his incarceration, Niran Malaolu was not allowed
access to his lawyer, doctor or family members.
8. On 28th April 1998, after a secret trial, Niran Malaolu was found guilty
by the tribunal of the charge of concealment of treason and sentenced to
9. The Complainant further alleges that Niran Malaolu’s alleged involvement
in the coup is connected with the news stories published by his Newspaper on
the coup plot involving the then Chief of General Staff, Lt. General Oladipo
Diya, as well as other military officers and civilians who have also been
convicted by the tribunal and given sentences ranging from prison terms to
death by firing squad.
10. One of such stories was an article entitled "The Military Rumbles
Again", which was published in the Sunday Diet of 28th December 1997 based
upon the announcement by the Military Government of the alleged coup plot it
claims to have uncovered.
11. Further, the Complainant alleges that Niran Malaolu was denied the right
to be defended by lawyers of his choice, and instead, assigned a military
lawyer by the tribunal in contravention of the right to fair hearing.
12. The Special Military Tribunal which tried Niran Malaolu was neither
competent, independent nor impartial in that members of the tribunal were
hand-picked by the Head of State, General Sani Abacha, and the Provisional
Ruling Council (PRC) against whom the alleged offence was committed.
Besides, the President of the tribunal, Major-General Victor Malu is also a
member of the PRC, which is empowered by the Treason and Other Offences
(Special Military Tribunal) Decree No. 1 of 1986, to confirm the death
sentences passed by the tribunal. These are alleged to be in violation of
the rules of natural justice and, in particular, article 7 (b) of the
13. The arraignment and trial of Niran Malaolu, a civilian before the
Special Military Tribunal using special procedures is a breach of Principle
5 of the United Nations Principles on the Independence of the Judiciary and
article 7 of the Charter.
14. The Complainant alleges further that under the provisions of the Treason
and Other Offences (Special Military Tribunal) Decree No. 1 of 1986, which
established the tribunal that tried and convicted the accused, the right of
appeal to a higher judicial authority is completely extinguished and those
convicted may only appeal to the PRC, which composition and interests are as
indicated in paragraph 12 above.
15. The Author also contends that the trial of Niran Malaolu in camera was a
violation of recognised international human rights standards, to wit: the
right to a fair and public hearing.
16. Finally, that the arrest, detention, arraignment, trial, conviction and
sentence of Malaolu were in grave breaches of the norms of fair trial as
guaranteed in the Charter.
17. The Author alleges that the following articles of the African Charter on
Human and Peoples’ Rights have been violated:
Articles 6, 7, 9 and 26.
18. At its 25th ordinary session held in Bujumbura, Burundi, the Commission
decided to be seized of the communication, and requested the Secretariat to
notify the Nigerian Government. It also requested the Secretariat to submit
an opinion on the admissibility of the communication, particularly in
accordance with Article 56(7) of the Charter, vis-à-vis Nigeria's current
19. On 19th August 1999, the Secretariat of the Commission notified the
parties of this decision.
20. At its 26th ordinary session held in Kigali, Rwanda, the Commission
declared the communication admissible and requested parties to submit
written arguments on the merit of the case.
21. On 17th January 2000, the Secretariat notified parties of the above
22. On 17th February 2000, the Secretariat received a Note Verbale from the
High Commission of the Federal Republic of Nigeria in Banjul, referring to
the above Note Verbale and requesting the Commission to forward the
following documents to the country's competent authorities to enable them
prepare for appropriate responses to the alleged violations:
a) The Draft Agenda for the 27th ordinary session and the letter of
invitation to the session from the Secretariat;
b) A copy of the complaint that was attached to the Secretariat’s Note;
c) A copy of the Report of the 26th ordinary session
23. Further to the above request, the Secretariat of the Commission on 8th
March 2000, forwarded all the documents as requested, except the Report of
the 26th ordinary session, together with a copy of the summary and status of
all pending communications against Nigeria, a copy each of the three
communications (Nos. 218/98, 224/98 and 225/98) as submitted by their
authors, and a copy of the written response of the Complainant on the merits
of this communication.
24. At its 27th ordinary session held in Algeria, the Commission reviewed
the case and postponed its further consideration to the next session to
enable the government of Nigeria respond to its request for arguments on the
merits of the case.
25. On 31st May 2000, the Secretariat received a letter from the Complainant
inquiring about the decision of the Commission at the 27th ordinary session.
26. The above decision was communicated to parties on 6th July 2000. The
Secretariat also acknowledged receipt of the Complainant's letter of 31st
27. On 27th September 2000, the Secretariat received a response from the
High Commission of the Respondent State in the Gambia intended to be
arguments on the merits of communications 224/98 and 225/98. The facts
therein however focused on the former communication.
28. On 3rd October 2000, the Secretariat of the Commission acknowledged
receipt of Note Verbale and indicated the discrepancy. Also, a copy of the
submission was forwarded to the Complainant for its observations.
29. During the session of the Commission in Benin, the Respondent State
submitted additional arguments on the matter.
STATE PARTY'S RESPONSE
30. The Government of Nigeria contends that the trial was conducted under a
law which was validly enacted by the competent authority at that time. The
Treason and Other Offences (Special Military Tribunal) Act, Cap 444 of the
Laws of the Federation of Nigeria, 1990 under which Malaolu was tried arose
from the ashes of the Treason and Other Offences (Special Military Tribunal)
Decree No.1 of 1986 enacted by the Military government headed by General
Ibrahim Babangida (Rtd.). Malaolu was, therefore charged, tried, convicted
and sentenced to life imprisonment in accordance with the provisions of a
31. The Government argues that Malaolu was tried along with a number of
people accused of involvement in alleged plot to overthrow the late Gen.
Sani Abacha. It asserts that without going into the merits or demerits of
the trial, it was not an ostensible case of victimisation against Malaolu or
his profession. Indeed, one or two other journalists were also sentenced to
imprisonment at the same trial.
32. It claims that the whole episode took place during a prolonged military
regime. It is well known all over the world that military regimes are
abnormal regimes and a painful aberration. There was no way of controlling
any wanton acts of abuse of fundamental rights by a military junta
determined to stay in power at all costs, no matter whose ox was gored.
33. In respect of the allegation that the trial was not fair, it argued that
the right to fair hearing in public was subject to the proviso that the
court or tribunal might exclude from the proceedings persons other than the
parties thereto in the interest of defence, public safety, public order,
34. The government of Nigeria affirms and reiterates its capacity and
determination to defend and promote the rights of its citizens and intends
to provide effective and adequate representation at the hearing of the case.
ADDITIONAL RESPONSE BY STATE PARTY
35. Mr. Malaolu was arrested, detained, tried and convicted under an
existing legislation made by a “legitimate” military administration, which
was imposed on the people of Nigeria. Be that as it may, the military regime
of General Abdulsalami Abubakar, caused Mr. Malaolu to be granted pardon and
he can institute an action in the ordinary courts on violation of his rights
and also petition the Judicial Commission of Inquiry of Human Rights
violations. Meanwhile, the obnoxious enactment has been repealed.
36. At its 25th ordinary session held in Bujumbura, Burundi, the Commission
requested the Secretariat to give its opinion on the effect of article 56(7)
of the Charter in view of the prevailing political situation in Nigeria.
Relying on the case law of the Commission, the Secretariat submitted that
based on the well established principle of international law, a new
government inherits the previous government’s international obligations,
including responsibility for the previous government’s misdeeds (see Krishna
Achutan and Amnesty International / Malawi, communications 62/92, 68/92 and
37. The commission has always dealt with communications by deciding upon the
facts alleged at the time of submission of the communication (see
communications 27/89, 46/91 and 99/93). Therefore, even if the situation has
improved, such as leading to the release of the detainees, repealing of the
offensive laws and tackling of impunity, the position still remains that the
responsibility of the present government of Nigeria would still be engaged
for acts of human rights violations which were perpetrated by its
38. Furthermore, the Commission noted that although Nigeria is under a
democratically elected government, the new constitution provides in its
section 6(6)(d) that no legal action can be brought to challenge ‘any
existing law made on or after 15 January, 1966 for determining any issue or
question as to the competence of any authority or person to make any such
39. For the above reasons, and also for the fact that, as alleged, there
were no avenues for exhausting local remedies, the Commission declared the
40. The Complainant alleges that the arrest and subsequent detention of
Malaolu was arbitrary as he was neither shown any warrant of arrest nor
informed of the offences for which he was arrested. Further, that Malaolu
was arrested by armed soldiers from the Directorate of Military Intelligence
at his office on 28 December 1997 and detained incommunicado at a military
facility in Lagos until he was moved to Jos, where his trial took place.
41. This, it is contended, is in contravention of Article 6 of the African
Charter on Human and Peoples’ Rights. The said article provides inter alia:
Every individual shall have the right to liberty and to the security of his
person. No one may be deprived of his freedom except for the reasons and
conditions previously laid down by law. In particular, no one may be
arbitrarily arrested and detained.
42. Further to this, the Complainant alleges that until 14 February 1998
(that is, about two months after his arrest) when he was arraigned before a
Special Military Tribunal for his alleged involvement in a coup, Mr. Malaolu
was neither informed of the reasons for his arrest nor of any charges
43. In its Resolution on the Right to Recourse Procedure and Fair Trial, the
Commission had, in expounding on the guarantees of the right to fair trial
under the Charter observed thus:
… the right to fair trial includes, among other things, the following:
(b) Persons who are arrested shall be informed at the time of arrest, in a
language which they understand of the reason for their arrest and shall be
informed promptly of any charges against them;
44. The failure and/or negligence of the security agents who arrested the
convicted person to comply with these requirements is therefore a violation
of the right to fair trial as guaranteed under Article 7 of the Charter.
45. Complainant alleges a violation of article 7 (1) (a) of the African
Charter on Human and Peoples’ Rights which states:
Every individual shall have the right to have his cause heard. This
(a) The right to an appeal to competent national organs against acts
violating his fundamental rights as recognised and guaranteed by
conventions, laws, regulations and customs in force;
46. Complainant contends that the decision of the Tribunal which tried and
convicted Malaolu is not subject to appeal, but confirmation by the
Provisional Ruling Council, the composition of which is clearly partisan.
Non-compliance of the competent authorities of Nigeria to this requirement
is in breach of the provision of Article 7(1)(a) of the Charter.
47. Complainant alleges a violation of article 7(1) (b) of the Charter which
Every individual shall have …the right to be presumed innocent until proven
guilty by a competent court or tribunal
The Complainant alleges in this respect that prior to the setting up of the
tribunal, the Military Government of Nigeria organised intense pre-trial
publicity to persuade members of the public that a coup plot had occurred
and that those arrested in connection with it were guilty of treason. In
this regard, it alleges further, any possible claim to national security in
excluding members of the public and the press from the actual trial by the
tribunal cannot be justified, and therefore in breach of the right to fair
trial, particularly, the right to presumption of innocence.
48. The Government has not contested the veracity of the Complainant's
submissions. In this circumstance, the Commission is obliged to accept this
as the facts of the case and therefore finds the Government of Nigeria in
violation of Article 7(1)(b) of the Charter.
49. The Complainant alleges that the exclusion of the members of the public
and the press from the actual trial by the tribunal was not justified, and
therefore in breach of the right to fair trial.
50. The Government argues that the right to fair hearing in public was
subject to the proviso that the court or tribunal might exclude from the
proceedings persons other than the parties thereto in the interest of
defence, public safety, public order, etc.
51. Neither the African Charter nor the Commission's Resolution on the Right
to Recourse Procedure and Fair Trial contain any express provision for the
right to public trial. That notwithstanding, the Commission is empowered by
Articles 60 and 61 of the Charter to draw inspiration from international law
on human and peoples' rights and to take into consideration as subsidiary
measures other general or special international conventions, customs
generally accepted as law, general principles of law recognised by African
States as well as legal precedents and doctrine. Invoking these provisions,
the Commission calls in aide General Comment 13 of the UN Human Rights
Committee on the right to fair trial. Paragraph 6 of the said Comment
The publicity of hearings is an important safeguard in the interest of the
individual and of society at large. At the same time Article 14, paragraph
1, acknowledges that courts have the power to exclude all or part of the
public for reasons spelt out in that paragraph. It should be noted that,
apart from such exceptional circumstances, the Committee considers that a
hearing must be open to the public in general, including members of the
press, and must not, for instance, be limited only to a particular category
52. The exceptional circumstances under the International Covenant on Civil
and Political Rights, which the above Committee monitors are for reasons of
morals, public order or national security in a democratic society, or when
the interest of the private lives of the parties so requires, or to the
extent strictly necessary in the opinion of the court in special
circumstances where publicity would prejudice the interests of justice. The
Commission notes that these circumstances are exhaustive, as indicated by
the use of the phrase "apart from such exceptional circumstances"
53. The Government has only presented an omnibus statement in its defence to
the effect that the right to fair hearing in public was subject to the
proviso that the court or tribunal might exclude from the proceedings
persons other than the parties thereto in the interest of defence, public
safety, public order, etc. It has not specifically indicated which of these
circumstances prompted it to exclude the public from such trial. The
Commission therefore considers the argument not sufficient enough to avail
the Government of Nigeria such defence.
54. Considering the fact that as alleged by the Complainant, prior to the
setting up of the tribunal, the Government had organised intense pre-trial
publicity to persuade members of the public of the occurrence of a coup and
the involvement of those arrested in connection to it, the Commission is
constrained to find the exclusion of the same public in the actual trial
unjustified and in violation of the victim's right to fair trial guaranteed
under Article 7 of the Charter.
55. It is alleged that prior to his arraignment, precisely, for the 49 days
he was detained, Mr. Malaolu was not allowed access to his lawyer, neither
was he given the opportunity to be represented and defended by a Lawyer of
his own choice at the trial. Rather, he was assigned a military Lawyer by
the Tribunal. The Complainant submits that by refusing Mr. Malaolu access to
his lawyer, the government of Nigerian was in contravention of Article 7(1)
(c) of the Charter which provides:
Every individual shall have the right to defence, including the right to be
defended by counsel of his choice.
56. In its Resolution on the Right to Recourse and Fair Trial, the
Commission in re-enforcing this guarantee observed in paragraph 2 (e) (i)
In the determination of charges against individuals, the individual shall be
entitled in particular to:
(i)…communicate in confidence with counsel of their choice
The denial of this right therefore is a violation of these basic guarantees.
57. The Complainant alleged that the Special Military Tribunal which tried
the convicted person was neither competent, independent nor impartial
because members of the Tribunal were selected by the Head of State, General
Sani Abacha, and the Provisional Ruling Council (PRC), against whom the
alleged offence was committed. Some members of the Tribunal are also serving
army officers. For instance, the President of the Tribunal, Major-General
Victor Malu is also a member of the Provisional Ruling Council, which is
empowered by the Treason and Other Offences (Special Military Tribunal)
Decree No. 1 of 1986, to confirm the sentences passed by the Tribunal. This
is a breach of the right to a fair trial as stipulated in article 7(1) (d)
of the Charter.
Article 7 (1) (d) states:
Every individual shall have… the right to be tried… by an impartial court or
58. The Government has not refuted this specific claim. It only states that
the Treason and Other Offences (Special Military Tribunal) Act, Cap 444 of
the Laws of the Federation of Nigeria, 1990 under which Malaolu was tried
arose from the ashes of the Treason and Other Offences (Special Military
Tribunal) Decree No. 1 of 1986 enacted by the then Military Government
headed by General Ibrahim Babangida (Rtd.). Further, it asserts that its
submission would not address the merits or demerits of the trial.
59. The Commission is not taking an issue with the history and origin of the
laws nor the intention why they were promulgated. What is of concern here to
the Commission is whether the said trial conforms to the fair hearing
standards under the Charter. The Commission is of the opinion that to answer
this question, it must necessarily consider the merits or demerits of the
trial, an issue the Government does not want to be involved in.
60. Consequently, the Commission finds the selection of serving military
officers, with little or no knowledge of law as members of the Tribunal in
contravention of Principle 10 of the Basic Principles on the Independence of
Judges. The said Principle states:
Persons selected for judicial office shall be individuals of integrity and
ability with appropriate training or qualifications in law.
61. In the same vein, the Commission considers the arraignment, trial and
conviction of Malaolu, a civilian by a Special Military Tribunal, presided
over by serving military officers, who are still subject to military
commands, without more, prejudicial to the basic principles of fair hearing
guaranteed by Article 7 of the Charter.
62. It is fitting, in this regard, to cite the Commission's general position
on the issue of trials of civilians by Military Tribunals. In its Resolution
on the Right to Fair Trial and Legal Assistance in Africa, the Commission
had, while adopting the Dakar Declaration and Recommendations noted thus:
"In many African countries Military Courts and Special Tribunals exist
alongside regular judicial institutions. The purpose of Military Courts is
to determine offences of a pure military nature committed by military
personnel. While exercising this function, Military Courts are required to
respect fair trial standards."
2. They should not, in any circumstances whatsoever, have jurisdiction over
civilians. Similarly, Special Tribunals should not try offences that fall
within the jurisdiction of regular courts.
63. The Commission considers the said trial, which has not been refuted by
the Respondent State, save to the extent that it was done under a law
validly enacted by the competent authority at the time, in contravention of
the right to fair trial guaranteed under Article 7 of the Charter. The
Commission also finds the setting up of the said tribunal for the trial of
treason and other related offences as impinging on the independence of the
judiciary, in as much as such offences are being recognised in Nigeria as
falling within the jurisdiction of the regular courts.
64. The Commission also finds the trial in contravention of the basic
principle of fair hearing contained in Principle 5 of the United Nations
Basic Principles on the Independence of the Judiciary (The UN Basic
Principles) and article 7 (1) (d) of the African Charter. Principle 5 of the
UN Basic Principles stipulates:
Everyone shall have the right to be tried by the ordinary courts or
tribunals using established legal procedures. Tribunals that do not use the
duly established procedures of the legal process shall not be created to
displace the jurisdiction belonging to the ordinary courts or judicial
65. Furthermore, in its General Comment on a similar provision of Article 14
of the International Covenant on Civil and Political Rights, the Human
Rights Committee observed:
The provisions of article 14 apply to all courts and tribunals within the
scope of that article whether ordinary or specialise. The Committee notes
the existence, in many countries, of military or special courts which try
civilians. This could present serious problems as far as the equitable,
impartial and independent administration of justice is concerned…While the
Covenant does not prohibit such categories of courts, nevertheless the
conditions which it lays down clearly indicate that trying of civilians by
such courts should be very exceptional and take place under conditions which
genuinely afford the full guarantees stipulated in article 14.
(See also its Comment on the Report of Egypt - UN Doc. CCPR/79/Add. 3,
paragraph a of August 1993)
66. It could not be said that the trial and conviction of Malaolu by a
Special Military tribunal presided over by a serving military officer, who
is also a member of the PRC, a body empowered to confirm the sentence, took
place under conditions which genuinely afforded the full guarantees of fair
hearing as provided for in Article 7 of the Charter. This is also in
contravention of Article 26 of the Charter which states:
State parties to the present Charter shall have the duty to guarantee the
independence of the courts and shall allow the establishment and improvement
of appropriate national institutions entrusted with the promotion and
protection of the rights and freedoms guaranteed by the present Charter.
67. It is also contended by the Complainant that Malaolu is being punished
by Nigeria’s Military Government over news stories published by his
Newspaper relating to an alleged coup plot involving Nigeria’s’ Chief of
Staff and Second -in- Command, Lt. General Oladipo Diya and other military
officers and civilians. This is alleged to be in contravention of his right
to freedom of expression enshrined in Article 9 of the Charter.
68. The Government argues that Malaolu was tried along with a number of
people accused of involvement in alleged plot to overthrow the late Gen.
Sani Abacha. It contends that the trial was not an ostensible case of
victimisation against Malaolu or his profession, but rather that one or two
other journalists were also sentenced to imprisonment at the same trial.
69. Considering the facts at the disposal of the Commission and the response
of the Government, the Commission takes the view that it was only Mr.
Malaolu’s publication which led to his arrest, trial and conviction and
therefore finds that in violation of Article 9 of the Charter as alleged.
70. The Complainant avers that while Mr. Malaolu was in detention, he was
subjected to such cruel, inhuman or degrading treatment, as having his legs
and hands chained to the floor day and night. From the day he was arrested
and detained, until the day he was sentenced by the tribunal, a total period
of 147 days, he was not allowed to take his bath. He was given food twice a
day, and while in detention, both in Lagos and Jos before he faced the
Special Investigation Panel that preceded the trial at the Special Military
Tribunal, he was kept in solitary confinement in a cell meant for criminals.
The Complainant submits further that the treatment meted out to Mr. Malaolu
contravened Article 5 of the Charter. Article 5 provides:
Every individual shall have the right to the respect of the dignity inherent
in a human being and to the recognition of his legal status. All forms of
exploitation and degradation of man particularly slavery, slave trade,
torture, cruel, inhuman or degrading punishment and treatment shall be
Principle 1 of the Body of Principles for the Protection of All Persons
under Any Form of Detention or Imprisonment provides:
All persons under any form of detention or imprisonment shall be treated in
a humane manner and with respect for the inherent dignity of the human
Further, Principle 6 states:
No person under any form of detention or imprisonment shall be subjected to
torture or to cruel, inhuman or degrading treatment or punishment. No
circumstance whatever may be invoked as a justification for torture or other
cruel, inhuman or degrading treatment or punishment.
71. It is worth noting that the term ‘cruel, inhuman or degrading treatment
or punishment’ is to be interpreted so as to extend to the widest possible
protection against abuses, whether physical or mental.
72. The Government has not denied these allegations. Indeed, it has made it
clear that it is not contesting the merits or demerits of the case. In the
absence of any information to the contrary from the Government, the
Commission finds the various forms of treatments meted to Mr. Malaolu while
in detention, in violation of the victims right to respect and dignity and
right to freedom from inhuman or degrading treatment guaranteed under
Article 5 of the Charter and reinforced by the above Basic Principles. (See
communications 64/92, 68/92 and 78/92 ( Krishna Achuthan on behalf of Aleke
Banda, Amnesty International on behalf Orton and Vera Chirwa) / Malawi),
communications 27/89, 46/91, 49/91 and 99/93 ( Organisation Mondiale Contre
La Torture and Association Internationale des Juristes Démocrates,
Commission Internationale des Juristes (C.I.J), Organisation Mondiale Contre
La Torture and Union Interafricaine des Droits de l'Homme / Rwanda),
73. Although not an issue, the Commission notes that the alleged violations
took place during a prolonged military rule and that such regimes, as
rightly pointed out by the Government are abnormal (see the Commission's
Resolution on the Military, adopted at the 16th ordinary session in Banjul,
the Gambia). The Commission sympathises with the Government of Nigeria over
this awkward situation but however asserts that this does not in any way
diminish its obligations under the Charter, nor the violations committed
prior to its coming into office.
74. Finally, the Commission finds it necessary to clarify the position
regarding the claim of the Government of Nigeria to the effect that the
trial was conducted under a law validly enacted by the competent authority
at the time. Also that the victim was charged, tried, convicted and
sentenced in accordance with the provisions of such a law.
75. In this regard, the Commission recalls its decision in communication
147/95 and 149/96, Sir Dawda Jawara /The Gambia, wherein it stated thus:
"For a State to avail itself of this plea, it must show that such a law is
consistent with its obligations under the Charter". It is therefore not
enough for a State to plead the existence of a law, it has to go further to
show that such a law falls within the permissible restrictions under the
Charter and therefore in conformity with its Charter obligation. No such
reasons have been adduced in the instant case. The Commission therefore
rejects this argument.
FOR THESE REASONS, THE COMMISSION
Finds the Republic of Nigeria in violation of Articles 3(2), 5, 6, 7 (1)
(a), (b), (c), (d), 9 and 26 of the African Charter and Principle 5 of the
UN Basic Principles on the Independence of the Judiciary.
Urges the Republic of Nigeria to bring its laws in conformity with the
provisions of the Charter.
Done at the 28th session held in Cotonou, Benin from 23rd October to 6th