TRAINING OF HUMAN RIGHTS

LAWYERS ON PUBLICT INTEREST

LITIGATION IN ZANZIBAR
AUGUST, 19TH – 20TH 2021
GOLDEN TULIP STONETOWN
BOUTIQUE
Strategic Litigation before Regional
Mechanisms (EACJ and African
Court): Best Practices
Robert V. Makaramba
Judge (Retired)
SYNOPSIS STRATEGIC


INTRODUCTION
LITIGATING LITIGATION
BEFORE REGIONAL
MECHANISMS FOR THE
 At the East African
Court of Justice
 At the African Court
PROTECTION OF
on Human and
Peoples’ Rights HUMAN RIGHTS
 EMERGING
JURISPRUDENCE & BEFORE
BEST PRACTICES
 EACJ
 African Court
REGIONAL
 CONCLUSION
MECHANISMS
 Playing the Devil’s Advocate
A devil’s advocate is a “person who expresses an opinion
that disagrees with others so that there will be an
interesting discussion about some issue.”[Collin’s
Dictionary]
Lord Diplock, “The fundamental human right is not to a
legal system that is infallible but to one that is fair.”
[Mahara vs. Attorney General of Trinidad and Tobago
1978(2), All England Law Reports 670]
Themis, the Goddess of Justice
 Perception of Justice
 The blindfold: justice is impartial and is
administered without fear or favour.

 The pair of scales: justice is done after

weighing the strength of the competing
claims.

 The sword symbolizes the power to

enforce it.
Lord Chief Justice Hewart aphorism: “Justice should not
only be done but should manifestly and undoubtedly be
seen to be done.” [R v Sussex Justices, ex parte McCarthy
([1924] 1 KB 256, [1923] All ER Rep 233)].
It imposes positive obligations on judicial office-holders.
If a hearing is seen as having been unfair by those
involved, directly or indirectly, or the public at large, then
it has not been satisfactory.
Professional Conduct and Etiquette
 The legal profession: Judges & practicing
lawyers (enrolled advocates)
 Essential ingredients of professionalism:
 character,
 competence,
 commitment, and
 civility.
 Trial Advocacy
Horrible, Terrible no Good Mistakes
Lawyers Make in Public Interest Litigation
1.Not taking their client’s case seriously –
remember the Six Ps: Proper Planning and
Preparation Prevents Poor Performance.
Going to Court unprepared: use the court’s
cause list to find out the time, the
courtroom/chamber and the presiding judge for
your client’s case.

Not sticking to the Court Timings: adjust your

schedule (diary) according to the court timings
(courts’ diary).
2. Not being very well versed with the facts
of your client’s case, the law and the
applicable rules of procedure.

3. Not knowing your documents and the

cross references to the bundle.
4. Not knowing how to present your
claims/defenses at the hearing.

Being repetitive - don’t fall into the temptation of

not conceding positions or admit claims when it is
clear the facts are not going your way.
5. Not understanding the importance and use of
pre-trial conference procedures and how to utilize
ADR mechanisms (mediation)

6. Not listening to the answers being given by the

witness and not knowing when to stop keep
pressing and when to stop.
7. Don’t be afraid of silence: think before you
answer - silence is a virtue so they say.
 Don’t argue with the Judge - be respectful to
the Bench in your responses and courteous to
your fellow learned brothers and sisters.
8. Practice to excel in the art of cross-
examination.

 Sometimes there may be drama in the

courtroom, which may make it look like a
theatre; learn the art of persuasion and
evoking emotions.
6. Know Your Judge
• Stick to the Court Timings: adjust your schedule
(diary) according to the court timings (courts’
diary), not your diary.
• Organize your information and
communication: it is as important for the lawyers
to understand what is being said to them as it is for
them to be understood.
• Space Dominance: The parties/advocates
and Judges are set well apart from each
other – be audible.
• Time management - during judicial
proceedings in courts the timing of events is
monopolised by the Judge.
 Beyond Absurdity - a court of law,
like the theatre, is an area where
both social values and the devices
employed to choose between them
can be studied.
 Turn off any electronic device before you
enter the courtroom.
 Leave food and drinks outside the
courtroom.

 Dress properly: observe formal court

attire, no fancy clothes or styles or
“shouting” colours.
Observe Court Protocol
 Bow before the Judge when you enter the
courtroom - you are bowing to the authority of the
Judge (state power).

 Address your Judge properly: Remember the

judge’s name and the correct mode to address him
or her – “My Lord”, “Your Lordship”, “Madame
Judge” etc.
 Observe Seniority and Order of
Precedence: You should always be
introduced by a Senior Counsel.
 Remember to introduce the individuals
present in court with you and their
respective roles.
 Obey court/judge’s orders: be courteous
in your responses: use the magical words
-“much obliged.”

 Don’t take the goings in court personal -

be emphatic not sympathetic.
 Be audible and speak with clarity: make
short submissions and be right to the
point.
 KISS – Keep It Short and Simple - use
short sentences, avoid the temptation of
verbose and use of archaic language
(Latin).
The KISS Rules:

 FILAC: Facts, Issues, Law, Argument

(Reasons), Conclusion

 LOPP: The Losing Party Position

 FLOPP: Flaws in the Losing Party Position.

 Write you submissions as if you are writing

judgment for the winning party.
 Mind your body language; watch your
client’s demeanour and yours as well.

 Remember that the courtroom is

designed to be reflective of the triviality
of the parties/advocates.
 The Concept of Strategic Litigation

• Selecting and bringing a case to the courtroom with

the goal of creating broader changes in society (social
change agent).

• Strategic cases are concerned with the effects that they

will have on larger populations and governments as
they are with the end result of the cases themselves.
 The Concept of Strategic Litigation

• Advocates for social justice can use the courts to bring about
legal and social change.

• SL can spring a government into action to provide basic care

for its citizens, guarantee the equal rights of vulnerable
groups, or halt an environmentally damaging activity.

• SL is not designed to provide the best services to the largest

number of people possible.
 Essentials of strategic litigation
• It is a process, not a single legal intervention;
• It is often repeat litigation;
• The strategic litigator should be part of a
multidisciplinary team;
• It has a distinctive role as a social-change tool; and
• It is an advocacy tool to advance human rights
through the judicial process.
 Dialogical Activism
• Strategic litigation as a social-change tool involves some
element of dialogical activism: the democratic debate with
other branches of government and civil society that the
judiciary can generate when they examine certain cases.

• Creates an opportunity for legal activists and judges to

convene in a democratic debate around a specific case.
 The Four Conditions Test

• Based on Charles R. Epp’s book, The Rights Revolution:

Lawyers, Activists, and Supreme Courts in Comparative

Perspective (1998).

• (1) an existing rights framework

• Social change can only be achieved through the courts if

activists can identify and frame problems as rights violations.

 The Four Conditions Test

• (2) an independent and

knowledgeable judiciary;
• The legal system must allow for claims
to be brought based on violated rights.
 The Four Conditions Test

• (3) civil society organizations with the

capacity to frame social problems as
rights violations and to litigate.

• Civil society organizations must have the

capacity to litigate effectively.
 The Four Conditions Test

• (4) a network to support and leverage the

opportunities presented by litigation.

• Social change achieved through the courts

is sustainable only if there is a strong civil
society support network.
STRATEGIC LITIGATION FOR THE PROTECTION OF
FREEDOM OF EXPRESSION
Why Litigate?
 A legal wrong or a legal injury caused to a person or to a
determinate class of persons;
 Such a person or determinate class of persons are unable to
approach the court for relief
 Any member of the public can maintain an application for
appropriate direction.
Justice Justice Bhagwati, S.P. Gupta v. Union of India [1982] AIR
149
In his presentation yesterday, Advocate
Onesmo touched on what it means by
”Public Interest Litigation” [PIL] –
litigation designed to serve the purpose of
protecting rights of the public at large
through vigilant action by “public spirited
persons” and swift justice.
 PIL Misuse
“…by persons who file Public Interest Litigations just for the
publicity and those with vested political interests. The courts
therefore, need to keep a check on the cases being filed and ensure
the bona fide interest of the petitioners and the nature of the cause
of action, in order to avoid unnecessary litigations. Vexatious and
mischievous litigation must be identified and struck down so that the
objectives of Public Interest Litigation aren’t violated. The
constitution envisages the judiciary as ‘a bastion of rights and
justice.”

Brian Asin & 2 Others v. Wafula W. Chebukati & 9 Others

[2017] eKLR
Remember the following:
Litigation should be something of the
last resort.
Litigation must complement existing
efforts that advance the protection of
human rights and expand the rule of
law.
 Court cases regardless of outcome, require
further advocacy to ensure appropriate follow up
in the courts and with the government, as
appropriate.
 Strategic litigation of freedom of expression is a
powerful means of educating judges about the
relevant human rights law.
 STRATEGIC
LITIGATION FOR THE
PROTECTION OF
FREEDOM OF
EXPRESSION BEFORE
REGIONAL
MECHANISMS
 Regional Human Rights
Mechanisms

The African
The East The African
Commission
Africa on Human Court on
Court of and Human and
Justice Peoples’ Peoples’
Rights Rights
(EACJ) (AfCHPR) (ACtHPR).
Litigating at Regional Mechanisms: Forum
Choice

Focus areas

Best Practices
Human Rights Procedure and
and Emerging
Jurisdiction Practice
Jurisprudence
 Litigating HRs
at the East
African Court of
Justice
LITIGATING BEFORE REGIONAL MECHANISMS
 What is the legal basis for bringing claims?

 Who has the capacity to bring claims?

 What is limitation period for bringing claims?
 What is the admissibility criteria?
 What is the procedure for filing cases?
 What kind of remedies are available?

 Whether the decisions are binding

 How are the decisions enforced?

 Do the decisions have precedential value?

A summary of procedural steps:

 Applicant lodges claim (Reference etc.)

 Court’s Registrar acknowledges receipt of claim and

notifies Applicant by a letter.

 Registrar forwards copy of Application to Respondent

State.

 Registrar requests Respondent State to provide him

(Registrar), [within 30 days] of receipt of Application
names and addresses of its representatives and to
respond to the Application [within 60 days].
A summary of procedural steps
 Court Registrar by another letter forwards copy of
Application to Chairman of African Commission, and
through him, to Executive Council of African Union, and
to all other States Parties to Protocol on the African
Charter on Human and Peoples’ Rights on the
Establishment of the African Court on Human and
Peoples’ Rights.

 By a Note Verbale, Respondent State through its

Embassy acknowledges receipt of Registrar’s letter.
 Non-Government Organizations may submit request to
appear as amici curiae and their amici briefs to Court’s
Registrar.

 Respondent State submits its response to the Application,

with observations regarding admissibility of the
application, if any.

 Applicant may apply for provisional measures on which

the Court has to make a ruling.

 Court’s Registrar forwards copy of the Response to the

Applicant.
Applicant submits a Reply, where they may reject the
preliminary objections raised by the Respondent, if any.

Court receives written submissions and makes its ruling

on the preliminary objections.

If preliminary objection overruled, Respondent is

requested to submit its response to merits of the case
within thirty (30) days of its Ruling; and Applicant to
submit his/her brief on the merits of the case within thirty
(30) days from the date of receipt of the response of the
Respondent State.
 Court Registrar notifies parties of date and place of hearing of
the case

 Hearing is conducted either in public or in private as the Court

may determine.

 At the hearing, parties and representatives of organizations

appearing as amici make their oral submissions and
observations.

 During the hearing the presiding Judges may put questions to the
parties and upon conclusion of the hearing, the Court renders it
decision.

 If the claim is successful, the parties are then invited to make

submissions on reparations.
 Note the adversarial nature of the proceedings before
Regional Courts.

 Whether the crafters should have explored more on the

possibility of using ADR mechanisms such as
arbitration, conciliation and mediation to resolve human
rights disputes (rights-based disputes).

 The EACJ has come up with Arbitration Rules, but we

have no record of its use by the Court.

 The common law tradition effect and impact; and the

training of the Judges (positivists).
For details on the procedures refer to:

THE EAST AFRICAN COURT OF JUSTICE RULES OF

PROCEDURE 2019 accessible at
https://
www.eacj.org/wp-content/uploads/2020/04/FINAL-PUBLI
SHED-EACJ-RULES-OF-PROCEDURE-2019.pdf

STATUTORY INSTRUMENTS SUPPLEMENT, No. 1 to

the East African Community Gazette No. 2 of 15th
February, 2019.
Printed by the Uganda Printing and Publishing
Corporation, Entebbe by Order of the East African
Community
AFRICAN COURT ON HUMAN AND PEOPLES’
RIGHTS [COUR AFRICAINE DES DROITS DE
L’HOMME ET DES PEUPLES], Rules of the Court
accessible at https
://www.african-court.org/en/images/Basic%20Documents/
Final_Rules_of_Court_for_Publication_after_Harmonizati
on_-_Final__English_7_sept_1_.
pdf

These Internal Rules shall replace the Interim Rules of

Procedure of 20 June 2008, following the harmonization of
the Interim Rules of the Court and the Commission carried
out during joint meetings in July 2009 in Arusha, October
2009 in Dakar and April 2010 in Arusha.
PROTOCOL ON THE STATUTE OF THE AFRICAN COURT OF JUSTICE
AND HUMAN RIGHTS Accessible at https://
www.african-court.org/en/images/Basic%20Documents/ACJHR_Protocol.pdf

The Protocol to the African Charter on Human and Peoples’ Rights on the
Establishment an African Court on Human and Peoples’ Rights, adopted by the
Assembly of Heads of States and Governments of the Organization of African Unity
on 10 June 1998 at Ouagadougou, Burkina Faso, and which entered into force on 25
January 2004;

The Protocol of the Court of Justice of the African Union, adopted by the
Assembly of the Union on 11 July 2003 in Maputo Mozambique;

The Protocol to the African Charter on Human and Peoples’ Rights

on the Rights of Women in Africa, and the commitments contained in the Solemn
Declaration on the gender equality in Africa Assembly/AU/Decl.12 (III) adopted by
the Assembly of the Union respectively at its Second and Third ordinary sessions
held in July 2003 and 2004, in Maputo, Mozambique and in Addis Ababa, Ethiopia);
EACJ: Best Practices and Emerging Jurisprudence
EACJ does not require exhaustion of domestic
remedies, thus opening the possibility of directly
challenging human rights issues (to the extent they can
be framed as a complaint about a violation of the East
African Community Treaty).
 This advantage is balanced out
considerably by the fact that the Court
adheres to a strict limitation period of 2
months from the moment the violation
took place and has explicitly rejected the
doctrine of continuing violations in the
case of Emmanuel Mwakisha Mjawasi
and Others v. The Attorney General of
Kenya
 See AfCHPR, Peter Joseph Chacha v.
Tanzania, App. No. 003/2012, Judgment of 28
March 2014, para. 142, accessible at http://
www.african-court.org/en/images/Cases/Judgm
ent/Ruling_Appl_003_2012.pdf
- where the African Court stated that
exhaustion of domestic remedies “is not a
matter of choice. It is a legal requirement in
international law.”
 Media Council of Tanzania, Legal and
Human Rights Centre & Tanzania
Human Rights Defenders Coalition vs
The Attorney General of the United
Republic of Tanzania. Accessible at
https://
www.eacj.org/wp-content/uploads/2019/
03/Referene-No.2-of-2017.pdf
Reference to challenge the Media Services
Act, No. 120 of 2016

 Cite specific articles in the human rights

treaty alleged to have been violated.

 Cite specific provisions in the impugned

law claimed to be violative of the treaty
provisions
Challenged provisions in the impugned law:
Type of news or content restricted
Mandatory accreditation of journalists
Criminal penalties when defamation is
established
Criminalization of production of false
news and rumours
Criminalization of seditious statements
Grant of absolute powers to Minister to
prohibit importation of publications, or
sanction media content.

State the reliefs sought

Costs and incidentals

State the reliefs sought

Matters of curiosity
 Among the Judges who sat, was a Judge
from Tanzania.
 The Court directed the Government of
Tanzania to take measures as are
necessary to bring the Media Services
Act, into compliance with the EAC
Treaty.
 The Court found and declared a number
of provisions in the impugned law as
being violative of Articles 6(d) and 7(2)
of the EAC Treaty.

 The Court categorized the Reference as

a public interest litigation due to the
matters involved which were of public
importance.
Articles 6(d) and 7(2) of the EAC Treaty

ARTICLE 6: Fundamental Principles of the

Community

The fundamental principles that shall govern

the achievement of the
objectives of the Community by the Partner
States shall include:
(d) good governance including adherence to
the principles of democracy, the rule of law,
accountability, transparency, social justice,
equal opportunities, gender equality, as well
as the recognition, promotion and
protection of human and peoples rights
in accordance with the provisions of the
African Charter on Human and Peoples’
Rights;
ARTICLE 7: Operational Principles of the
Community

2. The Partner States undertake to abide by

the principles of good governance, including
adherence to the principles of democracy,
the rule of law, social justice and the
maintenance of universally accepted
standards of human
rights.
Katabazi and 21 Others v Secretary General of
the East African Community and Another (Ref.
No. 1 of 2007) [2007] EACJ 3 (1 November 2007)
accessible at http://
www.saflii.org/ea/cases/EACJ/2007/3.html and

(Coram: Moijo M. ole Keiwua P, Joseph N.

Mulenga VP, Augustino S. L. Ramadhani J, Mary
Stella Arach-Amoko J, Harold R. Nsekela J)
Katabazi and 21 Others v Secretary General

 Invasion of the High Court premises by armed

agents of the Second Respondent,
 Re-arrest of the Complainants granted bail by
the High Court and their incarceration in prison
constitute infringement of the Treaty for the
Establishment of the East African Community
 Acts complained of violated one of the
fundamental principles of the Community
- rule of law.
Litigating HRs at
the African Court
on Human and
Peoples’ Rights
Emerging Jurisprudence and Best (Good)
Practices
Konaté v. Burkina Faso - the African Court
found a violation of the right to freedom of
expression under Article 9 of the African
Charter, Article 19 ICCPR and Article 66 of the
Revised ECOWAS Treaty.
 Separate opinion - what the Court should first deal
with; admissibility or jurisdiction. Lack of unanimity
from the Court on this particular issue.
 Dissenting opinion on the issue of provincial
measures, to wit, releasing the Applicant from prison
pending outcome of the case in the African Court.
 Zanzibar has criminal defamation in its statute books.
Tanzania Mainland scrapped it off some years back.
Criminalization of expression of speech by way of
criminal defamation laws
 Reframing the issues: whether the impugned national
laws are in conflict with international human rights
treaties.

 “Criminalization of expression of speech by way of

criminal defamation laws of any kind cannot be
justified – upholding it amounts to a step backward in
the evolution of human rights.”
 Can criminalization of defamation be
justified say for example in prohibiting
hate speech or incitement?

 Criminal defamation should be scrapped

off the statute books and relegated to the
civil wrong - the law of defamation
(tortious liability).
 “A Regional Court does not sit on appeal from the
decision of a national court. It only examines the
violation of international and regional human rights
treaties by States through its laws and executive
acts.”

 4 State duties: to Protect, Promote, Respect and

Fulfil.

 “Vertical obligation” as opposed to “Horizontal

obligation.”
Reparations: Damages and Human Rights

 Court’s earlier finding on reparation (use of

precedent) – is the Court bound by its own
previous decisions?

 Are the Court decisions binding on the

national courts from which the case originated
or any other Court in the State Party to the
Protocol?
AfCHPR: Beneficiaries of the Late Abdoulaye Nikiema
(Norbert Zongo) v. The Republic of Burkina Faso (2015)
[Claimants of Late Nobert Zongo, Abdoulaye Nikiema
alias Ablasse, Ernest Zongo and Blaise Liboudo and the
Burkinabe Movement on Human and Peoples’ Rights v.
Burkina Faso, App. No. 013/2011].

 Jurisdiction of the Court vis-à-vis admissibility of the

application: a judicial dilemma and quagmire.
 In the Zongo case, the matter concerned claims that the
Respondent State had failed to find and put to trial
the assassins of Norbert Zongo, an investigative
journalist and his companions, was a violation of
freedom of speech of Burkinabe journalists. Both the
magistrate court and the Court of Appeal of
Ougadougou dismissed the charges against the persons
who had been charged in connection with the murder
for lack of evidence.
 The ruling expanded what type of actions can
constitute violations of freedom of expression.

 That, not thoroughly investigating an attack on a

journalist, done in retaliation for a story, can be
considered a restriction on freedom of expression
because it can be conceived as working to intimidate
other journalists away from writing on issues and
thus restricting freedom of expression.
 Furthermore, the court’s extensive
remedies measures, including the
concession of damages and the order to
reopen the investigation, signal an
important step to achieve accountability
concerning human rights violations.
 The decision establishes a binding or
persuasive precedent within its
jurisdiction.

 Burkina Faso is a member state to the

African Court on Human and Peoples’
Rights and therefore is bound by the
decision of the court.
 Rev Christopher Mtikila vs Tanzania
(2014) on violation of freedom of
association, to wit, the right to
participate in public/governmental affairs
and the right against discrimination by
prohibiting independent candidates to
contest in Presidential Parliamentary and
Local Government elections.
 Application No. 009/2011 & 011/2011
Tanganyika Law Society, The Legal and Human
Rights Centre v The United Republic of
Tanzania and Reverend Christopher R. Mtikila v
The United Republic of Tanzania.

 Decision date: June 14, 2013

 Noteworthy the Court dealt
with the issue of determination
of admissibility first before
addressing itself to whether it
had jurisdiction to deal with
the mater.
 The Court noted that it is not enough to
show that a State has violated a
provision of the Charter - it is also
necessary to prove the damages, and
that in principle the existence of a
violation of the Charter is not per
se sufficient to establish a material
damage.
CONCLUSION
 Two regional courts, two different approaches
on a similar matter: HRs

 The EACJ although established by the EAC

Treaty, it does not expressly confer it with
jurisdiction over cases of violation of human
rights.

 The EAC does not have a human rights treaty.

 The African Court is a creature of a
Protocol to a regional human rights treaty.

 The Protocol confers on the Court very

wide jurisdiction in cases of violation of
human rights enshrined in international
and regional human rights treaties to
which State Party to the Protocol are
parties.
 A State must declare its willingness to
submit to the jurisdiction of the two
regional courts.

 Capacity to bring cases before regional

courts is broad - individuals and civil
society organizations may have recourse
against a State on behalf of victims for
violation of human rights.
 Decisions of the two regional courts are binding
on Member States but there are no national laws
on their enforcement.

 It is general principle that, a regional human

rights court does not sit on appeal from the
decisions of a national courts. It only examines
the violation of international and regional
human rights treaties by a State through its laws
and executive acts.
REFERENCES:

The Rights Revolution: Lawyers, Activists, and Supreme

Courts in Comparative Perspective by Charles R. Epp,
University of Chicago Press, 1998, 326 pp Accessible at
http://faculty.washington.edu/swhiting/pols398/Epp%20R
ights%20Revolution.pdf
Mashamba C.J., Litigating Human Rights in
African Institutions: Law, Procedures and
Practice, LawAfrica (2017).

Jason N.E Varuas, Damages and Human Rights,

Hart Publishing, Oxford and Portland, Oregon
(2016), pp.499 (the author makes a strong case for a
tort-based approach in damages in cases of violation
of human rights).
A Comparative Study on the Law and Practice
of
Reparations for Human Rights Violations,
September 2019. Accessible at
file:///C:/Users/User/Downloads/Comparative-S
tudy-on-the-Law-and-Practice-of-Reparations-f
or-Human-Rights-Violations.pdf
The European Court of Human Rights vis-a-vis the
African Court of Human and Peoples Rights
http
://www.acthprmonitor.org/the-european-court-of-human-
rights-vis-a-vis-the-african-court-of-human-and-peoples-
rights
/

Oloka-Onyango, Joe, Human Rights and Public Interest

Litigation in East Africa: A Bird’s Eye View (2015). The
George Washington International Law Review, Vol. 47,
2015, Accessible at https://ssrn.com/abstract=3621124
Yakaré-Oulé (Nani) J. Reventlow & Rosa Curling, The
Unique Jurisdiction of the African Court on Human
and People's Rights: Protection of Human Rights
Beyond the African Charter, 33 Emory Int'l L. Rev. 203
(2019). Available at:
https://scholarlycommons.law.emory.edu/eilr/vol33/iss2/
1
Court Manual: A Practical Guide to the Law and
Practice of the East African Court of Justice,
November 2020 accessible at https://
www.eacj.org/wp-content/uploads/2020/04/EACJ-Manu
al-11.25.2020.pdf

TREATY FOR THE ESTABLISHMENT OF THE

EAST AFRICAN COMMUNITY (As amended on 14th
December, 2006 and 20th August, 2007) accessible at
https://www.eacj.org//
wp-content/uploads/2012/08/EACJ-Treaty.pdf
African Charter on Human and Peoples' Rights
Date of Adoption: June 01, 1981
Date of last signature: May 19, 2016
Date entry into force: October 21, 1986

https
://au.int/sites/default/files/treaties/36390-treaty-00
11_-_
african_charter_on_human_and_peoples_rights_e.
pdf
Protocol to the African Charter on Human And
Peoples' Rights on the Establishment of an African
Court on Human and Peoples' Rights

Date of Adoption: June 10, 1998

Date of last signature: February 08, 2016
Date entry into force: January 25, 2004

https://au.int/sites/default/files/treaties/36393-treaty-001
9_-_
protocol_to_the_african_charter_on_human_and_people
srights_on_the_establishment_of_an_african_court_on_
human_and_peoples_rights_e.pdf
© 2021 Robert V. Makaramba
robertmakaramba67@gmail.com

“To deny people their

human rights is to
challenge their very
humanity.” –
Nelson Mandela

THANK YOU FOR YOUR

KIND ATTENTION!