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RAPPORTEUR
32nd Session: Commissioner Barney Pityana
33rd Session: Commissioner Barney Pityana
34th Session: Commissioner Andrew R. Chigovera
35th Session: Commissioner Andrew R. Chigovera
36th Session: Commissioner Andrew R. Chigovera
37th Session: Commissioner Andrew R. Chigovera
SUMMARY OF FACTS
1. The Complainant is Lawyers for Human Rights, a human rights NGO based in
Swaziland.
2. The Complaint was received at the Secretariat of the Commission on 3 June
2002 and is against the Kingdom of Swaziland which is a party to the African
Charter on Human and Peoples� Rights.
3. The Complainant states that the Kingdom of Swaziland gained independence
on 6 September 1968 under the Swaziland Independence Constitution Order, Act
No. 50 of 1968. The 1968 Constitution enshrined several fundamental
principles of democratic governance such as the supremacy of the
Constitution and separation of powers and clearly laid down procedures for
amending the Constitution.
4. The 1968 Constitution also provided for a justiciable Bill of Rights
which secured the protection of fundamental human rights and freedoms
including the right to freedom of association, expression and assembly
5. The Complainant alleges that on 12 April 1973, King Sobhuza /I issued the
King�s Proclamation to the Nation No. 12 of 1973 whereby he declared that he
had assumed supreme power in the Kingdom of Swaziland and that all
legislative, executive and judicial power vested in him. In addition, he
repealed the democratic Constitution of Swaziland that was enacted in 1968.
6. It is alleged that the King�s Proclamation resulted in the loss of the
protections afforded to the Swazi people under the Constitution�s Bill of
Rights, which effectively incorporated the rights ensured by the African
Charter.
7. According to the complaint, the provisions of the Proclamation outlawing
political parties violate the Swazi people�s freedom of association,
expression and assembly, thereby diminishing the rights, duties, and
freedoms of the Swazi people that are enshrined in the African Charter on
People�s and Human Rights.
8. Furthermore, it is alleged that the Swazi people do not possess effective
judicial remedies because the King retains the power to overturn all court
decisions, thereby removing any meaningful legal avenue for redress.
COMPLAINT
9. The Complainant alleges that the following Articles of the African
Charter have been violated: Articles 1, 7, 10, 11, 13,26
PROCEDURE
10. At its 32nd ordinary session, the African Commission decided to be
seized of the communication.
11. On 30 October 2002, the Secretariat informed the parties of the decision
of the African Commission and requested them to transmit their written
submissions on admissibility within a period of 3 months.
12. At its 33rd Ordinary Session held in Niamey, Niger from 15 to 29 May
2003, the African Commission examined the communication and decided to defer
its consideration on admissibility to the 34th Ordinary Session.
13. 0n 10 June 2003, the Secretariat of the African Commission wrote
informing the parties to the communication of the African Commission�s
decision and reminded them to forward their submissions on admissibility
within 2 months.
14. During its deliberations at the 34thOrdinary Session held from 6 to 20
November 2003 in Banjul, The Gambia, the African Commission however decided
to defer consideration of the communication
15. On 4 December 2003, the parties to the communication were informed of
the decision of the African Commission and requested the parties to forward
their written submissions on admissibility within 2 months.
16. At the 35th Ordinary Session held from 21 May to 4 June 2004 in Banjul,
The Gambia, the Complainant made oral submissions before the African
Commission. The African Commission considered the communication and declared
it admissible.
17. At its 36th Ordinary Session held in Dakar, Senegal from 23 November - 7
December 2004, the African Commission deferred consideration on the merits
of 33 the communication to give the Respondent State one more chance to
makes its submissions.
18. At its 37th Ordinary Session held in Banjul, The Gambia from 27 April to
11 May 2005, the African Commission considered the communication took a
decision on the merits thereof.
LAW
ADMISSIBILITY
19. The African Commission was seized with the present communication at its
32nd Ordinary Session which was held in Banjul, The Gambia from 17 to 23
October 2002. The Respondent State has since been requested numerous times
to forward its submissions on admissibility but to no avail. The African
Commission will therefore proceed to deal with this matter on admissibility
based on the facts presented by the Complainant.
20. Article 56 of the African Charter governs admissibility of
communications brought before the African Commission in accordance with
Article 55 of the African Charter. All of the conditions of this Article are
met by the present communication except Article 56 (5), which merits special
attention in determining the admissibility of this communication.
21. Article 56(5) of the African Charter provides:
�Communications...received by the African Commission shall be considered if
they:
(5) are sent after exhausting local remedies, if any, unless it is obvious
that this procedure is unduly prolonged.�
22. The rule requiring the exhaustion of local remedies as a condition of
the presentation of a communication before the African Commission is
premised on the principle that the Respondent State must first have an
opportunity to redress by its own means, within the fraIT1ework of its own
domestic legal system, the wrong alleged to have been done to the individual(s).
23. The Complainant submits that as a result of the King�s Proclamation to
the Nation No. 12 of 1973, the written and democratic Constitution of the
Kingdom of Swaziland enacted in 1968 containing a Bill of Rights was
repealed. Furthermore, the Proclamation prohibited the Courts of the Kingdom
of Swaziland from enquiring into the validity of the Proclamation or any
acts undertaken in accordance with the Proclamation.
24. The Complainant indicates that under the Proclamation, the King assumes
supreme power in the Kingdom and judicial power is vested in him and he
retains the power to overturn all court decisions, thereby removing any
meaningful legal avenue for redress. The Complainant quotes the case of
Professor Dlamini v The King to illustrate instances where the King has
exercised his power to undermine 34 � decisions of the courts. In that case,
the Court of Appeal overturned the Non-Bailable Offences Order of 1993,
which ousted the courts� jurisdiction to entertain bail applications.
Following the decision of the Court of Appeal, the King issued a Decree -
NO.2 of 2001 reinstating the Non Bailable Offences Order. However, due to
international pressure, the King later repealed aspects of the reinstated
Non Bailable Offenses Order by Decree NO.3 of 2001.
25. Therefore the Complainant argues they cannot exhaust domestic remedies
because they are unavailable by virtue of the Proclamation and even where a
matter could be instituted and won in the courts of Swaziland, it would not
constitute a meaningful, durable remedy because the King would nullify such
legal victory.
26. The Complainant provides all the Proclamations made by the King and
after perusing the Proclamations, the African Commission notes that no where
in all the Proclamations is there an ouster clause to the effect that the
Courts of the Kingdom of Swaziland are prohibited from enquiring into the
validity of the Proclamation or any acts undertaken in accordance with the
Proclamation.
27. The African Commission has considered this matter and realises that for
the past 31 years the Kingdom of Swaziland has had no Constitution.
Furthermore, the Complainant has presented the African Commission with
information demonstrating that the King is prepared to utilise the judicial
power vested in him to overturn court decisions. As such, the African
Commission believes that taking into consideration the general context
within which the judiciary in Swaziland is operating and the challenges that
they have been faced with especially in the recent past, any remedies that
could have been utilised with respect to the present communication would
have likely been temporary. In other words, the African Commission is of the
view that the likelihood of the Complainant succeeding in obtaining a remedy
that would redress the situation complained of in this matter is so minimal
as to render it unavailable and therefore ineffective2. For the reasons
stated herein above, the African Commission declares this communication
admissible.
DECISION ON THE MERITS
SUBMISSION FROM THE COMPLAINANT
28. The complainant submits that the Kingdom of Swaziland signed the African
Charter on Human and Peoples� Rights in 1991. The significance of the
signing is that the Kingdom declared an intention to be bound by the
Charter.3 The complainant submits further that on 15 of September 1995, the
Kingdom of Swaziland then ratified the Charter and by ratifying the Charter,
the Kingdom declared its final formal intention and declaration to be bound
by the provisions of the Charter. Formal agreements, particularly unilateral
agreements, normally require ratification in addition to the signature. This
requires the representative of the state subsequently to endorse the earlier
signature. This require-s the representative of the state subsequently to
endorse the earlier signature. This provides the state with an opportunity
to reconsider its decision to be bound by the treaty, and, if necessary, to
effect changes to its own law to enable it to fulfil its obligation under
the treaty.
29. The complainant notes that the Kingdom of Swaziland had ample time
between 1991 and 1995 to consider whether or not to formally agree to be
bound by the Charter or to change its laws to fulfil its obligations in
1995.
30. The complainant notes that the Respondent State has violated Article 1
of the African Charter as the latter imposes an obligation on Member States
of the African Union to adopt legislative or other measures to give effect
to the rights, duties and obligation enshrined therein, noting the African
Commission�s decision in Communication 147/95 and 149/965 where the African
Commission found that:
Article 1 gives the Charter the legally binding character always attributed
to international treaties of this sort. Therefore a violation of any
provision of the Charter automatically means a violation of Article 1. If a
State Party to the Charter fails to recognise the provisions of the same,
there is no doubt that it is in violation of this Article. Its violation,
therefore, goes to the root of the Charter.
31. The complainant states further that the African Commission found that
the obligation under Article 1 commences at ratification and that
ratification implies that the State party must also take pre-emptive steps
to prevent human rights violations.6 According to the complainant, it goes
without saying that the African Commission must declare the Proclamation to
be in violation of Article 1.
32. The complainant also alleges violation of Article 7 of the African
Charter noting that the Proclamation vests all powers of State to the King,
including Judicial powers and the authority to appoint and remove judges
which necessitates the conclusion that Courts are not independent,
especially in view of Decree No.3/2001. This Decree clearly ousts the Courts�
jurisdiction to grant bail on matters listed in the Schedule, which schedule
may be amended from time to time outside Parliament. The complainant made
reference to the African Commission�s decision in Communication 60/91, 7
where it was stated that:
Jurisdiction has thus been transferred from the normal courts to a tribunal
chiefly composed of persons belonging to the executive branch that passed
the Robbery and Firearms Decree, whose members do not necessarily possess
any legal expertise. Article 7 1(d) of the African Charter requires Courts
or tribunal to be impartial. Regardless of the character of the individual
members of such tribunals, its composition alone creates the appearance, if
not lack, of impartiality.
33. According to the complainant, Decree No.3 of 2001 is in violation of
Article 7, particularly Article 7 1(d) and the African Commission is urged
to find as such.
34. The complainant also alleges violation of Article 10 and alleges that
Sections 11, 12 and 13 of the Proclamation in very clear terms abolish and
prohibit the existence and the formation of political parties or
organisations of a similar nature. In this regard, the complainant quotes
Communication 225/988 and the African Commission�s Resolution on the Right
to Freedom of Association which provides that;
the competent authorities should not override constitutional provisions or
undermine fundamental rights guaranteed by the constitution and
international standard;
in regulating the use of this right, the competent authorities should not
enact provisions which would limit the exercise of this freedom;
the regulation of the exercise of the right to freedom of association should
be consistent with state�s obligations under the African Charter on Human
and Peoples� Rights
35. The Commission then concluded that the Nigerian Government�s acts
constituted a violation of Article 10 of the African Charter. Accordingly,
this Resolution equally applies to the Kingdom of Swaziland, and thus
Swaziland is in violation. With regards to allegations of violation of
Article 11, the complainant argues that the King�s Proclamation does not
only prohibit the right to associate but also the right to assemble
peacefully and adds that the right to associate cannot be divorced from the
right to assembly freely and peacefully. In this regard the complainant
cites the African Commission�s decision in Communications 147/95 and 149/96
where it stated that the Commission in its Resolutions on the Right to
Freedom of Association had also reiterated that the regulation of the
exercise of the right to freedom of association should be consisted with
States obligations under the African Charter on Human and Peoples� Rights
This principle does not apply to freedom of association alone but also to
all other rights and freedoms enshrined in the Charter, including, the right
to freedom of assembly.
36. The complainant also alleged violation of Article 13 of the African
Charter and stated that Section 8 of King�s Proclamation of 1981 provides
that �The provisions of section 11 and 12 of the King�s Proclamation of the
12th April, 1973 shall not be applicable to the Tinkundla which are hereby
declared and recognised as centres for meetings of the nation�. According to
the complainant the import of this section is that citizens can only
participate in issues of governance only within structures of the present
system, which does not allow free association and assembly, expression and
conscience (the Tinkhundla System of Government). In this regard, the
complainant refers to the Commission�s decision in Communication 147/95 and
146/96 Sir Dawda Jawara / The Gambia where it stated that the imposition of
the ban on former Ministers and Members of Parliament is in contravention of
their rights to participate freely in the government of their country
provided for under Article 13(1) of the Charter �Also the ban on political
parties is a violation of the complainantso rights to freedom of association
guaranteed under Article 10(1) of the Charter.
37. And Communication 211/989 which provides that the Charter must be
interpreted holistically and all clauses must reinforce each other. The
purpose or effect of any limitation must also be examined, as the limitation
of the right cannot be used to subvert rights already enjoyed. Justification,
therefore cannot be derived solely from popular will. as such, cannot be
used to limit the responsibilities of state parties in terms of the Charter
38. The complainant alleges further a violation of Article 26 of the African
Charter noting that a violation of Article 7 is relevant to Article 26 and
in this regard makes reference to Communication 52/91, Communication 54/91,
Communication 61/91, Communication 129/9410 in which the African Commission
found that while Article 7 focuses on the individual�s right to be heard,
Article 26 speaks of the institutions which are essential to give meaning
and content to that right. This Article clearly envisions, the protection of
the Courts which have traditionally been the bastion of protection of the
individual�s rights against the abuses of state power.
39. The complainant noted further that it is beyond doubt that the vesting
of judicial powers in the person of the King undermines the authority and
independence of the Courts, more so because the King with his legislative
powers can easily water down the decision of the Courts as was the case in
the jUdgment of Professor Dlamini v The King, Appeal Case No. 42/2000, where
the King by Decree NO.2 of 2001 overturned the Court of Appeal judgment by
reinstating the Non-Bailable offences Order which had been declared
unconstitutional.
40. The complainant prays the African Commission to:
find the King�s Proclamation of 12 April, 1973 to be in violation of the
African Charter on Human and Peoples� Rights; and
recommend and mandate strongly the Kingdom of Swaziland to take
constitutional measures forthwith to give effect to all the provisions of
the African Charter, specifically Articles 1, 7, 10, 11, 13 and 26 thereof.
COMMISSION�S DECISION ON THE MERITS
41. ln making this decision on the merits, the African Commission would like
to point out that it is disappointed with the lack of cooperation from the
Respondent State. The decision on the merits was taken without any response
from the State. As a matter of fact, since the communication was submitted
to the Commission and in spite several correspondences to the State, there
hasn�t been any response from the latter on the matter. Under such
circumstances, the Commission is left with no other option than to take a
decision based on the information at its disposal.
42. lt must be stated however that, by relying on the information provided
by the complainant, the Commission did not rush into making a decision. The
Commission analyzed each allegation made and established the veracity
thereof.
43. A preliminary matter that has to be addressed by the African Commission
is the competence of the commission to entertain allegations of human rights
violations that took place before the adoption of the Charter or even its
coming into force. In making this determination the Commission has to
differentiate between allegations that are no longer being perpetrated and
violations that are ongoing.
44. ln case of the former, that is, violations that occurred before the
coming into force of the Charter but which are no longer or which stopped
before the coming into force of the Charter, the Commission has no
competence to entertain them. The events which occurred before the date of
ratification of the Charter are therefore outside the Commission�s
competence rationae temp oris. The Commission is only competent ratione temp
oris to consider events which happened after that date or, if they happened
before then, constitute a violation continuing after that date.
45. ln the present communication, the violations are said to have started in
1973 following the Proclamation by the King, that is, prior to the coming
into force of the African Charter and continued after the coming into force
of the Charter through when the Respondent State ratified the Charter and is
still ongoing to date. The Commission therefore has the competence to deal
with the communication.
46. The Commission has competence ratione loci to examine the case because
the petition alleges violations of rights protected by the African Charter,
which have taken place within the territory of a State Party to that Charter.
It has competence ratione materFae as the petition alleges violations of
human rights protected by the Charter, and lastly it has competence ratione
temporis as the facts alleged in the petition took place when the obligation
to respect and guarantee the rights established in the Charter was in force
for the Kingdom of Swaziland. Given that Swaziland signed the Charter in
1991 and later ratified on 15 September 1995, it is clear that the alleged
events continues to be perpetrated when the State became under the
obligation to respect and safeguard all rights enshrined in the Charter,
giving the Commission rationae temporis competence.
47. The two stages of signature and ratification of an international treaty
provides states with the opportunity to take steps to ensure that they make
the necessary - domestic arrangements to ensure that by the time they ratify
a treaty the latter is in conformity with their domestic law. When ratifying
the Charter, the Respondent State was aware of the violation complaint of
and had the obligation to take all the necessary steps to comply with its
obligations under Article 1 of the Charter - to adopt legislative and other
measures to give effect to the rights and freedoms in the Charter.
48. From the above, it is the Commission�s opinion that it is competent to
deal with the matter before it.
49. Having determined that it is competent to deal with the matter, the
Commission will now proceed to examine each of the rights alleged to have
been violated by the Respondent State.
50. The complainant argues that by ratifying the African Charter and not
adopting legislative and other measures to bring the 1973 Proclamation in
conformity with the Charter, the respondent State has violated Article 1 of
the African Charter. The use of the terms �other measures� in Article 1
provides State Parties with a wide choice of measures to use to deal with
human rights problems. In the present situation when a Decree has been
passed by the Head of State abrogating the constitution, it was incumbent on
the same Head of State and other relevant institutions in the country to
demonstrate good faith and either reinstate the constitution or amend the
Decree to bring it in conformity with the Charter provisions during or after
ratification.
51. ln the opinion of the Commission, by ratifying the Charter without at
the same time taking appropriate measures to bring domestic laws in
conformity with it, the Respondent State�s action defeated the very object
and spirit of the Charter and thus violating Article 1 thereof.
52. The complainant also alleges violation of Article 7 of the Charter
stating that the Proclamation vests all powers of State to the King,
including judicial powers and the authority to appoint and remove judges and
Decree No.3/2001 which ousts the Courts� jurisdiction to grant bail on
matters listed in the Schedule. According to the complainant this
illustrates that Courts are not independent.
53. Article 7 of the African Charter provides for fair trial guarantees -
safeguards to ensure that any person accused of an offence is given a fair
hearing. In its resolution on Fair Trial adopted at its Eleventh Ordinary
Session, in Tunis Tunisia, from 2 to 9 March 1992, the African Commission
held that the right to fair trial includes, among other things, the right to
be heard, the right of an arrested person to be informed at the time of
arrest in a language he/she understands, of the reason for the arrest and to
be informed promptly of any charges against them, the right of arrested or
detained persons to be brought promptly before a judge or other officer
authorised by law to exercise judicial power and be tried within a
reasonable time or be released, the right to be presumed innocent until
proven guilty by a competent court.
54. In the present communication the Proclamation of 1973 and the Decree of
2001 vested judicial power in the King and ousted the jurisdiction of the
court on certain matters. The acts of vesting judicial power in the King or
ousting the jurisdiction of the courts on certain matters in themselves do
not only constitute a violation of the right to fair trial as guaranteed in
Article 7 of the Charter, but also tend to undermine the independence of the
judiciary.
55. Article 26 of the Charter provides that States Parties shall have the
duty to guarantee the independence of the courts. Article 1 of the UN Basic
Principles on 41 the Independence of the Judiciary 11 states that �the
independence of the Judiciary shall be guaranteed by the State and enshrined
in the Constitution or the law of the country. It is the duty of all
governmental and other institutions to respect and observe the independence
of judiciary.� Article 11 of the same Principles states that �the term of
office of judges, their independence, security ...shall be adequately
secured by law.� Article 18 provides that �Judges shall be subject to
suspension or removal only for reasons of incapacity or behaviour that
renders them unfit to discharge their duties.� Article 30 of the
International Bar Association (IBA)�s Minimum Standards of Judicial
Independence12 also guarantees that �A Judge shall not be subject to removal
unless, by reason of a criminal act or through gross or repeated neglect or
physical or mental incapacity, he has shown himself manifestly unfit to hold
the position of judge� and Article 1(b) states that �Personal independence
means that the terms and conditions of judicial service are adequately
secured so as to ensure that individual judges are not subject to executive
control.�
56. By entrusting all judicial powers to the Head of State with powers to
remove judges, the Proclamation of 1973 seriously undermines the
independence of the judiciary in Swaziland. The main raison d�être of the
principle of separation of powers is to ensure that no organ of government
becomes to powerful and abuses its power. The separation of power amongst
the three organs of government - executive, legislature and judiciary ensure
checks and balances against excesses from any of them. By concentrating the
powers of all-three government structures into one person, the doctrine of
separation of power is undermines and subject to abuse.
57. In its Resolution on the Respect and the Strengthening on the
Independence of the Judiciary adopted at its 19th Ordinary Session held from
26th March to 4th April 1996 at Ouagadougou, Burkina Faso, the African
Commission �recognised the need for African countries to have a strong and
independent judiciary enjoying the confidence of the people for sustainable
democracy and development�. The Commission then �urged all State Parties to
the Charter to repeal all their legislation which are inconsistent with the
principles of respect of the independence of the judiciary, especially with
regard to the appointment and posting of judges and to refrain from taking
any action which may threaten directly or indirectly the independence and
the security of judges and magistrates�.
58. Clearly, retaining a law which vest all judicial powers in the Head of
State with possibility of hiring and firing judges directly threatens the
independence and security of judges and the judiciary as a whole. The
Proclamation of 1973, to the extent that it allows the Head of State to
dismiss judges and exercise judicial power is in violation of Article 26 of
the African Charter.
59. With regards allegation of violation of Articles 10 and 11, the
complainant submits that the Proclamation of 1973 abolishes and prohibits
the existence and the formation of political parties or organisations of a
similar nature and that the Proclamation also violates Article 11 - right to
assemble peacefully as the right to associate cannot be divorced from the
right to assembly freely and peacefully.
60. Article 10 of the African Charter provides that �every individual shall
have the right to free association provided that he abides by the law �And
Article 11 provides that every individual shall have the right to assemble
freely with others. The exercise of this right shall be subject only to
necessary restrictions provided for by law...� In Communication 225/9813 the
African Commission, quoting its Resolution on the Right to Freedom of
Association held that the regulation of the exercise of the right to freedom
of association should be consistent with state�s obligations under the
African Charter and in regulating the use of this right, the competent
authorities should not enact provisions which would limit the exercise of
this freedom. That the competent authorities should not override
constitutional provisions or undermine fundamental rights guaranteed by the
constitution and international standard. The Commission reiterated this in
communications 147/95 and 149/9614 and concluded that This principle does
not apply to freedom of association alone but also to all other rights and
freedoms enshrined in the Charter, including, the right to freedom of
assembly.
61. Admittedly, the Proclamation restricting the enjoyment of these rights
was enacted prior to the coming into effect of the Charter. However, the
Respondent State had an obligation to ensure thC;;1t the Proclamation
conforms to the Charter when it ratified the latter in 1995. By ratifying
the Charter without taking appropriate steps to bring its laws in line with
the same, the African Commission is of the opinion that the State has not
complied with its obligations under Article 1 of the Charter and in failing
to comply with the said duty, the prohibition on the establishment of
political parties under the Proclamation remained effective and consequently
restricted the enjoyment of the right to freedom of association and assembly
of its citizens. The Commission therefore finds the State to have violated
these two articles by virtue of the 1973 proclamation.
62. The complainant also alleges violation of Article 13 of the African
Charter claiming that the King�s Proclamation of 1973 restricted
participation of citizens in governance as according to the complainant the
import of sections 11 and 12 of the Proclamation is that citizens can only
participate in issues of governance only within structures of the Tinkhundla.
In Communications 147/95 and 146/96 Sir Dawda Jawara / The Gambia the
Commission held that the imposition of the ban on former Ministers and
Members of Parliament is in contravention of their rights to participate
freely in the government of their country provided for under Article 13(1)
of the Charter Also the ban on political parties is a violation of the
complainants rights to freedom of association guaranteed under Article 10(1)
of the Charter
63. In the present communication, the King�s Proclamation clearly outlaws
the formation of political parties or any similar structure. Political
parties are one means through which citizens can participate in governance
either directly or through elected representatives of their choice. By
prohibiting the formation of political parties, the King�s Proclamation
seriously undermined the ability of the Swaziland people to participate in
the government of their country and thus violated Article 13 of the Charter.
From the above reasoning, the African Commission is of the view that the
Kingdom of Swaziland by its Proclamation of 1973 and the subsequent Decree
NO.3 of 2001 violated Articles 1, 7, 10, 11, 13 and 26 of the African
Charter.
The Commission hereby recommends as follows:
- that the Proclamation and the Decree be brought in conformity with the
provisions of the African Charter ;
- that the State engages with other stakeholders, including members of civil
society in the conception and drafting of the New Constitution; and
- that the Kingdom of Swaziland should inform the African Commission in
writing within six months on the measures it has taken to implement the
above recommendations.
Adopted by the African Commission on Human and Peoples� Rights at its 37th
Ordinary Session held in Banjul, The Gambia, from 27th April to 11th May
2005. |
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