Recent detention centre visits in Cameroon raise concerns

In the Southwest region of Cameroon, Contra Nocendi International partners with its section in Cameroon, Contra Nocendi Cameroon, to promote access to justice and the practical exercise of rights afforded to persons in detention. As part of this work, Contra Nocendi Cameroon conducts regular detention centre visits to observe the standards of detention centres in light of international human rights law and Cameroonian law applicable to persons held in detention.

From November 2017 to mid January 2018, Contra Nocendi Cameroon staff visited detention centres in Buea on several occasions. The visits came with a backdrop of the on-going crisis plaguing the Anglophone regions and the resulting increase in incarceration rates in the region. During the visits CN Cameroon staff made observations with regards to the prisons conditions and collected baseline data on detainees. The detention centre observers noted that prolonged pre-trial detention was a major cause for concern, and the prevalence of detention of minors arrested during the crisis with some awaiting trial before the military tribunal for terrorism related charges. It was also noted with great concern that the number of detainees held in detention centres around the Southwest region has increased dramatically since the beginning of the Anglophone crisis.

Detention centre visits raised serious concerns of prolonged pre-trial detention as well as concerns of limited access to counsel. While Contra Nocendi Cameroon did provide some assistance, where possible, in obtaining competent legal counsel, the observers were very concerned by the serious limitations on access to counsel observed at detention centres. Additionally, observers were appalled with the fact that some detainees where in detention merely for not being able to afford bail, while others had been detained for merely not having identification. Such petty offenses as not having identification should not be an offense leading to detention. Contra Nocendi Cameroon and Contra Nocendi International made a joint submission to the Special Rapporteur on Prisons, Conditions in Detention and Policing in Africa last year calling for the decriminalization of such petty offenses offences throughout Africa. We will continue to push this issue as lacking identification should never be seen as justification for infringing upon a person’s right to liberty.

Contra Nocendi Cameroon continues to monitor conditions at detention centres throughout the region. Contra Nocendi International stands in solidarity with Contra Nocendi Cameroon in calling for the government of Cameroon to take durable steps to protect and promote the right to counsel for persons held in detention in the Southwest region. We will continue to be steadfast in our efforts to push for ending the practice that allows for the continued detention of persons for petty offenses merely because they cannot afford bail. We are also deeply concerned that civilians can be brought before military tribunals in direct contradiction to the international legal obligations of Cameroon.

Cameroon must respect its state reporting obligations

The Republic of Cameroon is currently three reports behind in its state reporting obligations to the African Commission on Human and Peoples’ Rights. The Commission is an important venue for regular dialogue on the human rights situations in countries party to the African Charter on Human and Peoples’ Rights and Cameroon’s disregard for its obligations is a missed opportunity for all interested parties to engage in an inclusive dialogue to facilitate positive developments in human rights protections in Cameroon.


The last time Cameroon submitted a report to the Commission only covered from 2008 to 2011. Before this report, there had only been one other report that covered from 2001 to 2003. So for the entirety of the state reporting procedure before the Commission, Cameroon has only provided reporting on 7 years. This is unacceptable. It limits civil society’s ability to use the Commission as a tool to peacefully air concerns about the human rights situation in Cameroon. It also limits the opportunity for the government to publicly highlight their efforts to promote human rights, which we have seen such as efforts to promote women’s rights.


The government of Cameroon must change course and adhere to its obligations to provide state reports to the African Commission on Human and Peoples’ Rights at regular intervals. Contra Nocendi calls upon the Government of Cameroon to embrace the African Commission on Human and Peoples’ Rights as a vital tool to promote human rights in Cameroon.

Contra Nocendi Disappointed in Burundi’s Stance on Same-sex Relations


Contra Nocendi International reiterates its disappointment in the situation in Burundi regarding the rights of same-sex citizens. Indeed, following the 29th and latest session of the Universal Period Review (UPR) of the United Nations, Burundi still refused to decriminalize same-sex sexual relations.

On 22 April 2009, Burundi adopted legislation n°1/05 article 567 of the penal code, stating that “anyone who has sexual relations with a person of the same sex is punishable by 3 months to 2 years in prison or a fine of BIF 50 000 to 100 000 or one of these sentences only”.

After the interactive dialogue where six countries (Iceland, Timor-Leste, Ecuador, Australia, Uruguay and Argentina) recommended decriminalizing homosexuality, Burundi’s final remark was to bluntly reject the case for decriminalization of same-sex sexual relations on the basis that “the mind-set in Burundi has not developed yet to allow for this”.

Contra Nocendi is sceptical of the reasoning behind this argument, as Burundi only criminalized sexual relations between same sex persons in 2009. Hence, even if the general mind-set in Burundi was to not tolerate homosexuality, the fact that it only became a criminal offence 8 years ago demonstrates how unnecessary its criminalization is. Moreover, as Contra Nocendi has previously demonstrated in a recent article, this law exacerbated the already-existing homophobic culture.

Consequently, Contra Nocendi joins the international community to urge the government of Burundi to decriminalize same-sex relations in order to not only influence changed mind-sets with regards to homosexuality, but also and more importantly, in order to respect and protect the freedoms and rights of all Burundians, regardless of sexual orientation.




Burundi’s refusal to cooperate with CoI ruling alarming

Contra Nocendi International is deeply concerned by Burundi’s refusal to recognize the Commission of Inquiry (CoI) on Burundi’s mandate during oral comments on the recent Universal Periodic Review (UPR), as the situation remains alarming in the country. An estimated 400,000 Burundians have fled their homeland while army, police and Imbonerkure continue to commit major violations of human rights.


Ever since the Human Rights Council established the CoI on Burundi through resolution 33/24 of September 2016, Burundi has been reluctant to cooperate with the Commission and authorize it to conduct visits to the country. In a letter dated 14th September 2017, from the Permanent Representative of Burundi addressed to the President of the Security Council at the United Nations, Burundi accused the Commission of being part of a plan to destabilize and destroy its sovereignty. It expressed its disapproval of the decision to set up the commission and claimed that no conclusions reached by the CoI can be invoked against it.


The Commission’s mandate has been renewed for one additional year by resolution 36/19 adopted on 4th October 2017. It involves the conduct of investigations into human rights violations and abuses in Burundi since April 2015, including their extent and whether they may constitute international crimes. It was further tasked to identify alleged perpetrators of human rights violations and abuses in Burundi with a view to ensuring full accountability.


The cooperation with Council mechanisms is a condition of membership, and Contra Nocendi International urges Burundi to comply with resolutions 33/24 and 36/19, and to cooperate with the CoI and facilitate its work. It calls on the United Nations to take necessary actions to put an end to the persistent non-compliance attitude of the country. Finally, Contra Nocendi would like to express its support for the CoI and believes that the situation in Burundi cannot improve if national authorities continue to stand in the way of international mechanisms to uphold human rights.

Rape as a Tool of Torture in Burundi


Following the publication of the report submitted by the Commission of Inquiry (CoI) on Burundi by the Human Rights Council on the 4th of September 2017, a great amount of human rights violations has been brought to light. Even so, though most of the violations mentioned in the report are regularly brought up, the use of rape and other sexual assaults on men as an instrument of torture came across as an atrocity that is too rarely addressed.


The Facts:


Since April 2015, the period in which President Pierre Nkurunziza announced he was submitting his candidacy for a third mandate, Burundi is witnessing a political crisis that does not seem to be abating. The Burundian population is enduring a grave wave of repression, mainly committed by “the Burundian security forces and the Imbonerakure”[1] (members of the youth movement of the party in power). According to the president of the CoI on Burundi, these assaults are mainly directed against young men being perceived as in opposition to the Burundian government.[2]


The Commission has evidenced in its report many cases of sexual violence and torture against men in detention. Testimonies given have revealed very harsh and brutal violence with notably rapes, genital mutilations, cases of forced nudity, and injection of unknown substances into genitals, often causing serious harm.


It has been explained by the victims that these torturous acts were committed with the aim of obtaining forced confessions regarding their participation in the anti-Nkurunziza protests, their affiliation to opposition groups, the localization of arms cache, information dealing with the functioning of these armed groups, or also, the denouncing of members of opposition groups[3]. The perpetrators of these assaults also justified their actions by the desire to punish the persons affiliated to opposition groups, aiming to achieve this through humiliation of the men and violation of their masculinity.


Although these two reasons directly expressed by the perpetrators of the sexual crimes are emphasized in the victims’ testimonies, the CoI concludes that more generally, these assaults were perpetrated with the aim to “decree a form of domination[4].


It is clear that the intent of sexual assaults on Burundian men depicts a political phenomena targeting the opposition and punishing even nonpartisan persons simply for being in opposition to the government. Indeed, as highlighted by Cécile Poully, there is a true “will to break a possible opposition”[5].



An Evil Kept Quiet:


Sexual violence and rapes as war tools are unfortunately common practice, especially towards women. However, it is also true that more and more men find themselves victims of these crimes. Sadly, these are victims that are heard or helped too rarely. Indeed, due to fear of stigmatization, reprisal, or rejection from the community, the latter hardly admit the specifics of the crime they have suffered. Consequently, it is then difficult to establish the reach of this phenomena, which can in part explain why the latter is too often neglected and not addressed.


As the Burundian judicial system makes the process of lodging a complaint in cases of rapes difficult, perpetrators of rape are not only protected by their status of law enforcement representative or member of the party, but also because the judicial system allows the impunity of their actions. Consequently, victims feel obliged to remain silent so as to avoid other threats or reprisals.


Specifically for the case of men being rape victims, the fact that homosexuality is penalized by the Burundian legislative system represents another obstacle for the latter to admit to the crime they endured.


The gender perspective on this topic is quite prominent. Indeed, Burundi being a patriarchal society, the idea that sexual assaults can also target men is completely refuted, and men having suffered these abuses are negatively stigmatized as having “lost” their masculinity, power and domination – all traits emanating from or associated with their gender.


Due to all these reasons, very few men admit to having been victims. However, the consequences of this silence are manifold for victims of these assaults. Generally, the psychological and physical health if victims are damaged. Indeed, by not speaking up, victims do not receive the care they need, which can worsen the consequences of the violence that they have suffered. Because of shame or fear of stigmatization, men do not admit to medical professionals what happened to them, and this can have immediate outcomes as well as longterm ones, such as “erectile dysfunction, urinary issues or chronic pains around the genitals”[6]. Psychologically, male victims of sexual aggressions also admitted “feeling a lack of sexual desire, a feeling of seclusion, or to be subject to post-traumatic stress”[7].




Sexual torture and assaults of the nature denounced above represent grave human rights violations, such as the right to the security of the person, the right to be protected against torture and other cruel, inhuman or degrading treatment, without taking into account the physical and psychological destruction of the victim.


It is important to stress the fact that, in addition to women, sexual assaults and crimes are also perpetrated on Burundian men in detention, with the aim to punish them for being members of groups opposed to the government.


Given that rape is often committed to assert certain domination, it is clear that the rape of men during periods of detention, based on the fact that the detained person is opposed to the government, is a means to prove the domination of the ruling party over Burundian citizens.


Burundi being a country with a culture or patriarchal tendencies, very few masculine victims of sexual assaults express or denounce what they endured, due to fear of stigmatization, rejection from their community or reprisals. This complicates a lot the gathering of data on the issue, and consequently the implementation of solutions to fight this problem. Data are even hard to get since Burundi does not let many NGOs operate on its territory and refused over and over again the intervention of the UN and other international organizations in the country.


It becomes therefore important to open the dialogue on men as victims of sexual assaults to eventually manage to de-stigmatize their situation, and to be able to develop appropriate responses to these crimes. To start, Contra Nocendi International would like to call out to the authorities responsible for care in detention centers and encourage them to be more diligent in assessing the detainees’ physical and psychological conditions during their medical care and follow-up. This could allow detainees’ victims of sexual crimes to be treated, all the while giving them the choice to open up if they so wish. This call out is also directed at NGOs and other international organizations involved in the refugee camps in neighboring countries, where a significant number of Burundians, already victims of such crimes flee, to seek care and protection.


This article is by Maylis David, Advocacy Associate, Contra Nocendi



[1] Paragraph 5 of the 33/24 resolution

[2] Oral presentation by M. Fatsah Ougergouz, President of the Commission of Inquiry on Burundi during the interactive dialogue on Burundi of the 36th session of the Human Rights Council

[3] Rapport final détaillé de la Commission d’enquête sur le Burundi, Conseil des Droits de l’Homme, trente-sixième session, 11-19 septembre 2017 (Detailed final report of the Commission of Inquiry on Burundi, Human Rights Council, 36th session, 11-19 September 2017)

[4] Id.

[5] [5]

[6] Rapport final détaillé de la Commission d’enquête sur le Burundi, Conseil des Droits de l’Homme, trente-sixième session, 11-19 septembre 2017 (Detailed final report of the Commission of Inquiry on Burundi, Human Rights Council, 36th session, 11-19 September 2017)

[7] Id.

The right to counsel




The right to fair trial is recognized by the international community as a fundamental human right necessary in any democratic society governed by the rule of law. Various international instruments such as the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights, as well as, regional instruments such as the African Charter on Human and People’s Rights have enshrined this right.


According to article 7 of the African Charter, in order to ensure the respect of the right to fair trial, several other rights have to be guaranteed. They are intrinsic elements of the right to a fair trial. The focus will be put on one of these rights, the right to counsel.


The African Commission on Human and People’s Rights and the African Court on Human and People’s Rights had likewise, the opportunity to respond to complaints apropos of the right to counsel. Both bodies have strived to ensure the respect of this essential right. From their jurisprudence, it is therefore possible to identify general standards, which can be used to complete the international and regional legislation applicable on the matter.


This jurisprudence analysis will focus on the three major violations of the right to counsel: the lack of access to counsel (A), the delayed access to counsel (B), and the restricted access to counsel (C).


A- No access to Counsel


According to article 7.1. of the African Charter, each individual has the right to have his cause heard. Article 7.1.c further specifies that this right comprises the right to defence, including the right to be defended by a counsel of one’s choice. Hence, the right to counsel consists of two components: the right to be assisted by a counsel and the right to choose a counsel.


The African Commission in its communications has repeatedly reaffirmed the first component. In Media Rights Agenda, Constitutional Rights Project, Media Rights Agenda and Rights Project v Nigeria, the Commission stated that every individual has the right to defence and to be denied access to a lawyer is a violation of article 7.1.c of the African Charter[1]. In Purohit and Moore v The Gambia (Purohit), it further added that in the circumstances where the decision has the potential of touching among others the life of the persons concerned, the rights to be heard and represented become necessary[2].


Purohit dealt with the Lunatics Detention Act, a legislation, enacted in 1917 and last reviewed in 1964, governing mental health in Gambia. It particularly regulated the detention of mentally disabled individuals in an extremely arbitrary and discriminatory way. Besides several flaws in the legislation, such as the lack of a valid and objective definition of the term “lunatic”, it did not supply individuals, once detained with any means to challenge their detention nor access a lawyer.


The second component of the right to counsel is equally essential. It ensures that a counsel whom he trusts represents the accused. It also prevents the State from nominating a counsel that could be neither fully qualified nor independent. The Commission has further developed this right in Law Office of Shazi Suleiman v Sudan. The defendants, civilians, were tried under a military court, accused of the offence of destabilizing the constitutional system. The military court was established by Presidential decree and composed mainly of military officers. It was empowered to make its own rules of procedure, which did not have to conform to established rules of fair trial. In particular, the court had the right to veto the choices of counsel of the defendants leading to them being refused the right to assistance of defenders of their choice.


The Commission held that the court should not have a right to veto the choice of a counsel. It stated that “to recognize that the court has the right of veto on the choice of a counsel amounts to an unacceptable violation of this right”. It added that to avoid lawyers being prevented from assisting in given cases, there should be an objective system of registration of lawyers. Finally, it stated that it is essential that the national Bar is an independent organ which regulates the profession of lawyers and that courts do no longer play this role contrary to the right to defence[3]. This communication is particularly interesting as it identifies minimum standards and measures that can be adopted by States to ensure the independence of their legal profession.


Lastly, to ensure that the right to counsel is fully fulfilled, it appears that when individuals are not able to afford or access legal representation, judicial assistance should be provided. Article 14.3.d of the International Covenant on Civil and Political Rights states that each individual who faces criminal charges shall be tried while being present and has the right defend himself in person or through legal assistance of his own choosing. He has the right to be informed that if does not have legal assistance, he is entitled to have legal assistance assigned to him without any payment by him if he does not have sufficient means to pay for it.


Although regrettably missing from the African Charter, both the Commission and the Court implemented this right in their respective case law. In Working Group on Strategic Legal Cases v Democratic Republic of Congo, the Commission clearly stated that when an individual is not in position to afford legal counsel, it is the responsibility of the State to provide one. It judiciously added that the legal counsel should not however be imposed on the accused by the State[4]. The accused should be able to choose out of a list the preferred independent counsel.


The Court adopted a similar position in Alex Thomas v United Republic of Tanzania[5], basing its legal reasoning on the letter of article 14.3.d of the Covenant.


In all the communications and decisions mentioned previously both the Court and Commission had no difficulty to conclude to a violation of either article 7.1.c of the African Charter or Article 14.3.d of the Covenant. Indeed, most the complaints addressed to the two bodies were unambiguous. The defendants were clearly deprived from legal counsel or from the opportunity to freely choose their lawyer. The question becomes more intricate when dealing with other aspects of the right to counsel.


B- Delayed Access


If article 7.1.c of the African Charter clearly established the right to counsel, it does not however provide any time frame within which the council should intervene to defend his client. The question of prompt access to counsel is crucial and often not addressed by legal instruments such as the African Charter. As the right to counsel is a guarantee for individuals that their other fundamentals rights will be respected during their detention and trial, the counsel should be able to intervene as soon as possible for this guarantee to be effective.


On this matter, the Commission and the Court concluded that a delayed access to counsel constitutes a clear violation of article 7.1.c of the African Charter. Notwithstanding what has just been said the question seems to remain partly unanswered, as the appreciation of what is delayed can seem quite subjective. After how many days can the access to counsel be qualified as delayed? Do other circumstances affect this qualification such as the gravity of the offence committed? What reasons can a State invoke to justify the delayed intervention of a counsel? It seems that this could be an aspect that is assessed case by case, in concreto, by the judge. It does not preclude however a need for some guidelines.


These guidelines regrettably cannot be found in the jurisprudence, of the Commission or the Court, here analyzed. In all the cases studied, the applicants were denied access to counsel for a significant amount of time. In Abdel Hadi, Ali Radi & Others v Republic of Sudan, the Commission held that more than nine months without access to counsel constitutes a violation of article 7.1.c[6]. In Media Rights Agenda v Nigeria, 49 days without access to a counsel was held to be a violation of article 7.1.c[7]. In Mohamed Adubakari v United Republic of Tanzania, the African Court found that the fact for the applicants of not having access to a lawyer for about two months affected their ability to effectively defend themselves[8]. Neither the Court nor the Commission really detailed their reasoning in the matter.


It could be because the cases can be seen as quite straightforward in the sense that the time during which the applicants were deprived of counsel was significant. As the violations appeared obvious, the regional bodies did not seem to feel the need to dwell on the question. Therefore, from the analysis of these cases alone, the question of delayed access to counsel is not fully answered and deserves to be treated more in depth.


At the lecture of a relatively recent communication, Egyptian Initiative for Personal Rights and Interights v Egypt, further answers could be at first glance identified. In this communication, the victims were tried and sentenced to death after being accused of bombings, which took place on 6 October 2004 and 23 July 2005 on the Sinai Peninsula in Egypt. After their arrest, the applicants were allegedly subjected to various forms of torture and ill-treatment in order to confess. They were held incommunicado for a long period of time without access to a lawyer.


More specifically they did not have access to lawyers at the critical early interrogation stage and were later not able to consult with counsel privately. The Commission therefore emphasized the importance of being assisted by a counsel not only during trials but also at every step of a criminal prosecution. This includes preliminary investigations in which evidence is taken, periods of administrative detention, trial and appeal proceedings[9]. It is particularly crucial during investigations as the presence of a lawyer can constitute a safeguard against the use of torture and other ill-treatment.


A legal counsel should therefore be able to intervene at every step of a criminal procedure. Thus, if a counsel intervenes later than the first step in a criminal procedure, the access to counsel could be qualified as delayed. However, there are cases where individuals are arbitrarily detained without charges or investigations. They can be held for days, months or years in places of detention without any criminal procedure being started.


C- Restricted access


If the two previous parts of this article can be summarized as answering the questions “what” and “when”, this third and last one answers the question “how”. Indeed, to fulfill the right to defence not only individuals have to be promptly represented by a counsel but they have to be guaranteed a certain number of conditions so that the defence can be effective. There are three essential conditions, which should be respected to guarantee the right to defence.


Firstly, the applicant and its counsel should have all the necessary information to prepare their defence. In International Pen, Constitutional Rights Project, Civil Liberties Organization and Interights (on behalf of Ken Saro-Wiwa Jnr) v Nigeria, the defence was denied access to the evidence on which the prosecution was based. The files and documents, which were required by the accused for their defence, were removed from the lawyers’ residences and offices when security forces searched them on different occasions during the trial. The Commission held that withholding evidence from the defence constitutes at violation of article 7.1.c of the African Charter[10].


The Commission went further in Avocats Sans Frontières (on behalf of Gaetan Bwampamye) v Burundi, by explaining that at each stage, the accused and his counsel should be able to reply to the indictment of the public prosecutor and should be the last to intervene before the court retires for deliberations[11].


Secondly, the defence should be given enough time to prepare. For example, in Rights International v Nigeria, the applicant was arrested on 3rd January 1996 by unknown armed soldiers. He remained in a military detention camp until the 9th January 1996 and then transferred to the State Intelligence Bureau in Port Harcourt, Nigeria. He was held from the 9th until the 11th January 1996 without access to a legal counsel or his family. On the 9th, he was allowed to prepare a statement in his own defence without a legal counsel and brought before the Magistrate Court 2 in Port Harcourt on the 11th January. In this communication, not only the applicant did not have access to a counsel but also he was only given two days to prepare for his defence. The Commission held that it is important to provide individuals with adequate time to prepare their defence[12].


Lastly, individuals should be able to communicate in confidence with their counsel. The right to private and confidential communication with counsel is implied in Article 14.3.b of the Covenant. This article states that an accused should “have adequate time and facilities for the preparation of his defence and to communicate with counsel of his choosing”. When the confidentiality is not guaranteed it can lead to an imbalance between defence and prosecution.


The Egyptian Initiative for Personal Rights and Interights v Egypt communication can serve as an example to illustrate this last element. This particular communication comprises several violations of human rights such as the use of torture and other forms of ill-treatment, no access to medical assistance in places of detention and several violations of the right to fair trial. The focus will however be placed on the right to communicate in confidence with one’s counsel. When the applicants were granted access to a lawyer, their communications took place through bars of the courtroom, in the presence and within earshot of security official[13]. It led the Commission to state that lawyer-client communications should be held in confidence. This implies that facilities should be provided to ensure the confidence of any exchange[14].


The wording of the Commission is similar to the letter of article 14.3.b, however it is regrettable that this particular issue is very briefly mentioned in the communication. The Commission could have sized the occasion to emphasize further the importance of it. Particularly since the jurisprudence on the matter is quite scarce and there is a clear lack of standards regulating the issue.




From this analysis of the African Commission and African Court’s jurisprudence, it is possible to establish general standards, which serve to complete the international and national instruments establishing the right to counsel. The standards identified seem reasonably rounded and show the effort of both regional bodies to ensure the protection of this fundamental right.

Nonetheless, the legal reasoning behind some communications, mainly early ones, deserve further development not only to strengthen the Commission’s holdings but to serve a more pedagogic purpose. More recent communications seem to have settled this particular concern but not complete erased it.

Furthermore, certain aspects such as the question of prompt access to counsel, a question for which it seems more difficult to establish set in stone standards are not completely answered. Similarly, the jurisprudence of the Commission and the Court could gain from addressing more in details the right to private and confidential communication with counsel. As mentioned, there are very little cases that deal with this particular question. The issue is rarely mentioned by the defence, which alone should raise some questions. Regardless, when the question is raised, the Court and the Commission should draw standards applicable on the matter.

In conclusion, it seems quite apparent that there is room for further improvement in the jurisprudence of the two regional bodies, as certain standards needs to be clarified.


Photo credit: Open Society Justice Initiative (Nigeria)   


Article by Farah Jerrari, Program Associate, Contra Nocendi International 


[1] 105/93-128/94-130/94-152/96 Media Rights Agenda, Constitutional Rights Project, Media Rights Agenda and Rights Project v Nigeria, October 31, 1998, para 88.

[2] 241/01 Purohit and Moore v The Gambia, May 29, 2003, para 72.

[3] 222/98-229/99 Law Office of Shazi Suleiman v Sudan, May 3, 2003, para 59.

[4] 259/02 Working Group on Strategic Legal Cases v Democratic Republic of Congo, October 24, 2011, para 82.

[5] 005/2013 Alex Thomas v United Republic of Tanzania, November 20, 2015, para 123.

[6] 368/09 Abdel Hadi, Ali Radi & Others v Republic of Sudan, November 5, 2013, para 90.

[7] 224/98 In Media Rights Agenda v Nigeria, November 6, 2000, para 55.

[8] 007/2013 Mohamed Adubakari v United Republic of Tanzania, June 13, 2016, para 120 and 121.

[9] 334/06 Egyptian Initiative for Personal Rights and Interights v Egypt, March 1, 2011, para 209.

[10] 137/94-139/94-154/96-161/97 International Pen, Constitutional Rights Project, Civil Liberties Organization and Interights (on behalf of Ken Saro-Wiwa Jnr) v Nigeria, October 31, 1998, para 101.

[11] 231/99 Avocats Sans Frontières (on behalf of Gaetan Bwampamye) v Burundi, November 6, 2000, para 28.

[12] 215/98 Rights International v Nigeria, November 15, 1999, para 29.

[13] 334/06 Egyptian Initiative for Personal Rights and Interights v Egypt, 3 March 2011, para 134.

[14] 334/06 Egyptian Initiative for Personal Rights and Interights v Egypt, 3 March 2011, para 209.

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