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COMMUNICATION 839/24
Kenyi Yasin Abdallah
V
Republic of South Sudan
Adopted by the
African Commission on Human and Peoples' Rights
During the 85"' Orrlb,a,y Session _held in Banjulfrom 07 to 30 October 2025,
Banjul, The Gambia
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The African Commission on Human and Peoples' Rights
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31 Bijilo Annex Layout, Kombo North District, West Coast Region
Phone: (220) 230 4361 Fax: (220) 441 05 04
Email: au-banjul@africanunion.org
https:/achpr.au.int/0 o a
DECISION OF THE AFRICAN COMMISSION ON HUMAN AND
PEOPLES' RIGHTS ON ADMISSIBILITY
Communication 839/24 - Kenyi Yasin Abdallah v South Sudan
SUMMARY OF THE FACTS
1. The Secretariat of the African Commission on Human and Peoples' Rights (the
Secretariat) received a complaint on 26 January 2024 from Mr. Kenyi Yasin Abdallah
(the Complainant) on behalf of Civil Servants in the employ of the Government of
South Sudan (the Civil Servants or the Victims) against the Republic of South Sudan
(the Respondent State)1 .
2. The Complainant indicates that he is a South Sudanese human rights lawyer. He
alleges that the Respondent State has not remunerated the Civil Servants for six (6)
months and they have been subjected to economic hardship and starvation as a
result.
3. The Complainant alleges that the Respondent State has suppressed any attempt by
the aggrieved Civil Servants to protest their lack of pay through peaceful assembly.
The Respondent State, he alleges has threatened to shoot protesters.
4. The Complainant states that there has been between 2022 and 2024, several
incidents were teachers have attempted to protest the non-payment of salaries and in
all instances were arrested and detained by the military.
5. The Complainant avers that the Respondent State instead diverts funds towards the
payment of expensive International missions with large delegations as well as, the
purchase of luxury vehicles for senior government officials.
6. The Complainant argues that there is rampant corruption in the Ministry of Finance,
and that specifically in 2022 the Sudan People's Liberation Movement (SPLM)
members were paid advance salaries of four (4) months which he avers was unlawful.
1
8. The Complainant further submits that the Council of Ministers; National Legislative
Assembly; Judiciary and National Human Rights Commission were aware of this
situation.
ARTICLE(S) OF THE AFRICAN CHARTER ON HUMAN AND PEOPLES' RIGHTS
(AFRICAN CHARTER) ALLEGED TO HAVE BEEN VIOLATED
9. The Complainant alleges that the Respondent State has violated Articles 5, 11, 15
and 22 of the African Charter.
PRAYER
10. The Complainant therefore prays as follows:
i.
ii.
iii.
iv.
v.
vi.
vii.
A declaration that the policy of the Respondent State of prolonged Salary
delay constitutes exploitation, is inhumane and enabling starvation;
A decision requiring the Respondent State to strictly adhere to Article
57(1) of the Civil Service Act 2011;
A decision requiring the Respondent State to clear all salary arears of civil
servants both at National and State levels of Government;
A decision requiring the Respondent State to establish a Salaries and
Remunerations Commission in accordance with section 4.6.1.2 of the
Revitalised Peace Agreement;
A decision requiring the Respondent State to compensate every civil
servant with a six-month salary for the suffering they endured;
A decision requiring the Respondent State to reform her Human Rights
Commission to be independent and effective by incorporating
international standards of National Human Rights Institutions (NHRls) in
its operations and appointment of its Commissioners, and incorporating
prosecutorial powers and abolishing Section 30(3) of the Human Rights
Commission Act 2009 and Section 159 of the Code of Criminal Procedure
Act 2008; and
A decision requiring the Respondent State to compensate the
Complainant with USD30 000 for the costs of this communication.
THE PROCEDURE
11. The Secretariat received the Complaint on 26 January 2024.
14. The Complainant's submissions on Admissibility and Merits were received on 6 June
2024, and the African Commission on Human and People's Rights (the Commission)
acknowledged receipt on 28 June 2024.
15. The Complainant's submissions on Admissibility and Merits were transmitted to the
Respondent State on 28 June 2024 and the Secretariat requested the Respondent
State to make submissions on Admissibility and Merits, within sixty (60) days of
notification, in accordance with Rule 116 (2) of the Rules of Procedure of the
Commission, 2020 (ROP2020).
16. By Note Verbale dated 1 August 2024, the Respondent State replied to the
Secretariat, acknowledging receipt of the Note Verbale of the Secretariat forwarding
the submissions of the Complainants on Admissibility and Merits and requesting the
Secretariat provide the case file details for further action and consultations.
17. By email of 5 August 2024, the Secretariat re-forwarded the submissions of the
Complainants on Admissibility and Merits to the Respondent State. The Respondent
State did not forward its submissions on Admissibility and Merits on the
Communication.
THE LAW ON ADMISSIBILITY
Submissions of the Complainant on Admissibility
18. The Complainant submits that his Communication complies with the Admissibility
requirement stipulated by Article 56 of the African Charter.
19. The Complainant submits that the author of this Complaint is clearly indicated and
known by his name, occupation, address, contact, and nationality and that the author
has filed the Complaint on behalf of a group of victims who are extremely vulnerable
and legally, logical and practically unable to grant permission of legal representation
due to grave fear of retaliation, including termination of employment, arbitrary arrest
or detention by the army or national security agents.
20. The Complainant referred to the Commission's decision in Malawi African
Association and Others v Mauritania2 , where it was held that "Article 56(1) of the
African Charter demands that any persons submitting communications to the
Commission relating to human and peoples 'rights must reveal their identity. They do
not necessarily have to be the victims of such violations or members of their families.
This characteristic of the African Chanter reflects sensitivity to the practical difficulties
that individuals can face in countries where human rights are violated. ];frl~ afi.e~L
or international channels of remedy may not be accessible to th ~
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Communications No. 54/91-61/91-96/93-98/93-164/97_196/97-210/98 Malawi Afrr·~ As
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Complainant submits that pursuant to Article 56 (1) of the African Charter, the
author's representation of the victims is valid.
21. The Complainant submits that the Communication is compatible with the
Constitutive Act of the African Union (AU) and the African Charter, further that the
Complaint is not written in a disparaging language as the it is authored in a
respectful tone and language, with due respect to the AU, its Organs, and the
Respondent State, and is not based exclusively on news disseminated through the
mass media on official information of the Respondent State and documented
evidence, in compliance with Article 56(2), 56(3), and 56(4) of the African Charter.
22. Pursuant to Article 56(5) of the African Charter, the Complainant submits that
domestic remedies are not available for the civil servants as they are restricted
from suing the Respondent State and that the Civil Servants have a single institution,
the Employees Justice Chamber to file their Complaint and proceed to court
thereafter. However, the said institution, does not have jurisdiction to decide any
matter or grievance relating to: i.
matters that may impact on the Civil Service-wide workplace or
employment policies of the South Sudan Civil Service; or
ii.
the fixing of terms and conditions of employment. (Section 29 (5) of the
South Sudan Employees Justice Chamber Act, 2011 ).
23. According to the Complainant, the Complaint before the Commission is of a nature
that has impact on the civil service-wide workplace, as it relates to the treatment and
human rights violations of the entire civil servants. Moreover, the Complainant submits
that Section 19 of the Civil Service Act, 2011 did not provide for the right to legal
representation against the Respondent State, except the right to legal representation
against a third party. The Complainant submits that the Complaint is, equally against
institutions constitutionally mandated to protect human rights, including the Human
Rights Commission, the Legislative Assembly, the Ministry of Justice, the Judiciary
and the Employees Justice Chamber, who are also employers of the victims.
24. The Complainant further submits that South Sudan is governed by a military
Government that has been in constant violations of Article 3 (e), (g) and (h) of the AU
Constitutive Act and the military group of the Respondent State actively undermines
human rights in South Sudan. The Complainant argues that the persistent violation of
Article 3 (h) of the AU Constitutive Act undermines the very foundation of the African
Union. These conditions have effectively supplanted judicial authority with
reprehensible practices, leaving victims with no access to domestic human rights
remedy. The Complainant refers to Mouvement ivoirien de droits de /'Homme
-el rly
(MIDH) v. Cote d'/voire 3 where the Commission decided that, when it ap
that the Complainant does not have the qualification/possibility to use th
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remedies, the Commission considers that it is as if there is no locaJ. . ,, se~y'~ al (M)feo<"0 •
for the Complainant.
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25. Accordingly, the Complainant submits that the problems were known to the Council of
Ministers, including the President of South Sudan even before "the approval of the
budget for the financial year 2023-2024 in November 20234 . Yet, the Respondent State
to suppress protests and threats to use live bullets as public money is regularly being
squandered. The Complainant further argues that the Office of the President issued a
statement on its official Facebook page, which stands similar to a Government Gazette,
on 9 July2021, 24 November 2021, 16 December 2021, 26 May 2022 and 1 August
2022, acknowledging the violations suffered by the civil servants. The Minister of
Finance also issued a statement on 13 December 2023 and 20 January 2024,
acknowledging the same. 5
26. The Complainant indicates that Article 56 (5) of the African Charter requires that local
remedies, if any, be exhausted, unless these are unduly prolonged. The Complainant
referred to SERAC V. Nigeria: where the Commission held that, the exhaustion of
domestic remedies requirement should be properly understood as ensuring that the
State concerned has ample opportunity to remedy the situation of which applicants
complain. A state has more than sufficient opportunity to give domestic remedies when
it had ample notice over the past several years . .. and, where a right is not well provided
for in domestic law such that no case is likely to be heard, potential conflict does not
arise. Similarly, if the right is not well provided for, there cannot be effective remedies,
or any remedies at all.
27. The Complainant submits therefore, that the South Sudan Government, including the
Office of the President, has had ample notice of the human rights violations being
suffered by the civil servants. Instead of remedying the violations, the Respondent State
rather imposed terror on its citizens while regularly diverting public funds for private and
illegal purposes. The Complainant submits that with this state of affairs, there is logically
no domestic human rights remedy in practice, as the Respondent State perceives
human rights negatively, and as such the Article 56(5) of the African Charter has been
satisfied.
28. The Complainant submits that in accordance with Article 56(6) of the African Charter,
the Complaint is submitted within a reasonable time from the date the Annual Fiscal
Budget 2023- 2024 was passed in November 20236 . The Complainant avers that only
one salary for August 2023, from this amount has been paid to Civil Servants for the
budget period since 2023. The Complainant submits that with just a few months to the
next financial year, salaries for more than eight (8) months have not yet bee~ •·:i=atR
the last communication from the Minister of Finance in December 2023;t· - ~tQ9~f l'le-<11,
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intention to clear the salary arrears was futile and all attempts by the ,;- ~~tims"'
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express their voice on the matter were met with unprecedented forc~.p •
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5 (the Evidence list in pages 1 to 7 and the Approved Fiscal Budget 2023-2024),
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(i.e. the legal document that allocated 424.3 billion South Sudanese Pounds for wages and salaries).
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29. Regarding Article 56(7) of the African Charter, the Complainant submits that the
Communi'cation or any part of it is not a subject in any litigation or proceeding in any
court or other legal proceedings in any national, regional or international institution.
Respondent State's Submission on Admissibility
30. Despite the fact that the Commission requested the Respondent State to submit its
submissions and evidence on Admissibility and Merits in accordance with Rule 116
(2) of the ROP 2020, no response has been received.
31. In a situation where a State Party fails to submit its observations and evidence in line
with Rule 116 (2) of the ROP 2020, despite notice to that effect, the Commission has
no option but to proceed with its consideration of the Communication 7. Accordingly,
and in line with its existing jurisprudence, the Commission will analyze and determine
the Admissibility of the Communication based on the information supplied by the
Complainant in his submissions on Admissibility.
Analysis of the Commission on Admissibility
32. The Commission recalls that Article 56 of the African Charter governs the Admissibility
of Communications and sets out seven (7) requirements based on which the
Commission assesses the Admissibility of Communications submitted before it. For a
Communication to be deemed Admissible by the Commission, it must meet the (7)
requirements which apply conjunctively and cumulatively.
33. In relation to Article 56(1) of the African Charter states that "Communication relating
to Human and Peoples' Rights ... received by the Commission shall be considered if
they indicate their authors even if the latter request anonymity ... " The Complaint
received by the Commission indicates the author and he did not request anonymity.
The Commission therefore holds that the requirement under Article 56( 1) of the
African Charter is fulfilled.
34. Article 56(2) of the African Charter states that 'Communications ... received by the
Commission shall be considered if they are compatible with the Charter of the
Organisation of African Unity or with the present Charter', and in this Complaint the
Communication is brought against the Republic of South Sudan, a State Party which
ratified the African Charter on 23 October 2013. The Communication alleges violations
of the rights contained in the African Charter, in particular, rights guaranteed under
Articles 5, 11, 15 and 22 thereof. Given the fact that the Communication is compatible
with the AU Constitutive Act and the African Charter, the Commission therefore holds
that the requirements under Article 56(2) of the African Charter have been fulfilled.
35. Articled 56(3) of the African Charter states that "Communications .. .received by the
Commission shall be considered if they are not written in disparaging or insulting
language directed against the State concerned and its institutions or to the
Organisation of African Unity now African Union (AU)". The Commission is of the view
that the language used in the Communication is not written in disparaging or insulting
language directed at the State, its institutions or the AU and for these reasons, the
Commission finds that the requirements of Article 56(3) of the African Charter have
been fulfilled.
36. Article 56( 4) of the African Charter states that "Communications relating to human and
Peoples' Rights ... shall be considered if they are not based exclusively on news
disseminated through the mass media." There is no evidence in this Communication
which indicates that the allegations contained therein are based exclusively on news
disseminated through the mass media. The evidence provided is based official
information of the Government and documented evidence. For these reasons, the
Commission finds that the requirements of Article 56( 4) of the African Charter have
been fulfilled.
37. Article 56(5) of the African Charter, states that 'Communications should be 'sent after
exhausting local remedies, if any, unless it is obvious that this procedure is unduly
prolonged. This requirement is based on the fundamental principle that the
Respondent State must first have an opportunity 'to redress within its own domestic
legal system, the wrong alleged to have been done to the individuaf .8
38. The exhaustion of local remedies requirement is a fundamental principle of
international law ensuring the proper functioning of domestic legal systems and
granting national authorities the opportunity to address alleged violations before
international intervention. The Commission in its jurisprudence has held that
Complainants are required to exhaust local remedies if they are available, effective
and sufficient. A local remedy is considered available "if the petitioner can pursue it
without impediment, it is deemed effective if it offers a prospect of success, and it is
found sufficient if it is capable of redressing the Complaint9 .
39. In the present Communication, the Complainant argues that domestic remedies are
not available for the Civil Servants and puts forward the following arguments:
a) Civil Servants are restricted from suing the Respondent State and have a single
institution i.e., the Employee Justice Chamber, to file their complaint;
b) the Employment Justice Chamber does not have j •
determination about grievances relating to "civil service
policies, terms and conditions, which is the subject matter o
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relates to the treatment and human rights violations of the "entire civil servants
"of South Sudan;
c) victims face insurmountable obstacles in seeking justice and accountability; and
suppression by the Respondent State of any attempt by the aggrieved civil
servants to protest their lack of pay through peaceful assembly, including scores
of arrest, detention and threat to shoot protesters have supplanted judicial
authority with reprehensible practices, leaving victims with no access to domestic
remedy.
40. The Commission notes from the submissions before it that the present
Communication is brought on behalf of the entire civil servants of South Sudan 10 . The
Commission further notes the argument of the Complainant that the civil servants have
a single institution i.e., the Employee Justice Chamber, to file their complaint and
proceed to court thereafter, however the Employment Justice Chamber does not have
jurisdiction to make determination about grievances relating to civil service wide
employment policies, terms and conditions. Article 29(5) of the Southern Sudan
Employment Justice Chamber Act 2011 stipulates that "The Chamber does not have
jurisdiction to make a determination about any matter or grievance relating to- (a)
matters that may impact on the Civil Service-wide workplace or employment policies
of the Southern Sudan Civil Service Chamber". In accordance with the Article 29(5) of
the Employment Justice Chamber Act 2011 of the Respondent State, the Commission
agrees with the Complainant that the Employment Justice Chamber does not have
jurisdiction to hea.r the present Complaint.
41. Having determined that the Complaint cannot be determined by the Employment
Justice Chamber, the next domestic remedy that the Complainant should proceed to,
are the judicial courts in the Respondent State, in order to exhaust domestic remedies.
42. On this note, the Complainant argues that domestic remedies are not available and
gave examples of a series of instances of human rights violations, including arbitrary
arrest and detention of human rights defenders and civilians; several incidents were
teachers have attempted to protest the none-payment of salaries and in all instances
were arrested and detained by the military; and incidents where police fired live
ammunition during a youth protest regarding the sky rocketing prices of food.
Furthermore, the Complainant argued that because victims face insurmountable
obstacles in seeking justice and accountability with suppression by the Respondent
State of any attempt by the aggrieved civil servants to protest their lack of pay through
peaceful assembly with scores of arrest, detention and threat to shoot protesters11 ,
this have supplanted judicial authority with reprehensible practices, leaving victims
with no access to domestic remedy.
10
The government estimated that the number of its employees is 559,590-Approved Fiscal Bu
Year 2023 -2024
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11 The According to the Complainant, the Minister of Information who is the governm·
made a statement that " anyone who wants to protest should know that South Sudan ·, ·,
teargas, but only line bullets" . httP>.: J/ www.s udanspost.com/govt-re1wws- threats-qf;..~.,.,
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43. The Commission will now turn to its jurisprudence to determine whether under the
circumstance of this Communication and the arguments put forth by the Complainant,
this Communication falls within the category of Communications where exceptions to
the requirement to exhaust domestic remedies should apply?
44. According to the jurisprudence of the Commission, the principle of exhaustion of local
remedies requires that the Complainant or Victims provide some prima facie evidence
of an attempt to exhaust local remedies. Additionally, in Free Legal Assistance
Group and Others v Zaire 12 and Rencontre Africaine pour la Defense des Droits
de /'Homme v Zambia, 13 the Commission held that the requirement on exhaustion of
local remedies is founded on the principle that a Government should have the
opportunity to remedy such violations before approaching an international body.
45. Based on the facts before this Commission, the present Communication has not been
submitted to the domestic courts of the Respondent State for adjudication, because
according to the Complainant, victims face insurmountable obstacles in seeking
justice and accountability with suppression by the Respondent State of any attempt
by the aggrieved Civil Servants to protest their lack of pay through peaceful assembly
with scores of arrest, detention and threat to shoot protesters, and this have
supplanted judicial authorities with reprehensible practices, leaving victims with no
access to domestic remedy.
46. The Commission in Article 19 v Eritrea and Anuak Justice Council v. Ethiopia
held that "it is incumbent on the Complainant to take all necessary steps to exhaust,
or at least attempt the exhaustion of local remedies", adding that: "it is not enough for
the Complainant to cast aspersions on the ability of the domestic remedies of the State
due to isolated or past incidences". The Commission further held that "the argument
that local remedies are not likely to be successful, without trying to avail oneself of
them, will simply not sway this Commission".
47. Based on the above, the Commission is of the view that the Complainant's reliance
on incidents of threats, arrest and detention mainly during protests in the Respondent
State, is not adequate to cast aspersions on the futility of approaching the domestic
courts, and does not amount to a reasonable justification for not approaching the
domestic courts to exhaust local remedies. Consequently, the Commission finds that
the Complainant has not illustrated that the Civil Servants had taken any steps to
approach the Courts and that the arguments put forth fall under the exceptions of
exhaustion of local remedies principles.
from approaching the domestic courts. The Commission's application of the doctrine
of actio popularis does not prejudice the obligation of the authors of Communications
to exhaust domestic remedies, where such remedies exist and are reasonably
available. This ensures that reliance on actio popularis before the Commission does
not automatically exempt complainants from the requirement to exhaust domestic
remedies merely because such remedies are unavailable to actio popularis
Complainants at the domestic level. Rather, the exhaustion requirement continues to
be assessed in light of the availability and effectiveness of remedies within the
domestic legal system, consistent with the Commission's established jurisprudence.
Again, the Commission finds that the Complainant has not illustrated that the Civil
Servants, on whose behalf the Communication has been brought, had taken any steps
to approach the Courts as structured at the domestic level.
49. Furthermore, although the Commission acknowledges the Respondent State's duty to
investigate and administer justice for human rights violations, it is also essential for
the Commission to ensure that the Complainants have exhausted all available local
remedies through national judicial processes, to sort redress. Mere knowledge or
awareness of the violation by the Respondent State is insufficient to exempt the
Complainant from meeting this exhaustion of local remedies requirement. Instead, the
Complainant should have actively pursued all domestic remedies to provide the
Respondent State with the opportunity to address the alleged violations, through its
national mechanisms.
50. With the above findings therefore, the Commission holds that the requirement under
Article 56(5) of the African Charter has not been satisfied .
51. Article 56(6) of the African Charter states that Communications relating to human and
Peoples' Rights... shall be considered if they: are submitted within a reasonable
period from the time local remedies are exhausted, or from the date the Commission
is seized with the matter". The Complainant submits that the Complaint is submitted
within a reasonable time from the date the Annual Fiscal Budget 2023- 2024 was
passed in November 2023 14 . The Complaint was submitted to the Secretariat of the
Commission on 26 January 2024. The Commission has established jurisprudence,
such as in Promoting Justice for Women and Children (PROJUST NGO) vs. the
Democratic Republic of Congo, in which it held that where Article 56(5) of the
African Charter has not been complied with, there is no reason for proceeding to
consider Article 56(6) thereof, as it will be concluded that the latter _.s...oQt been
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complied with . As such, the Commission concludes that this Com
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52. With regards to Article 56 (7) of the African Charter , which provides that
"Communications relating to human and Peoples' Rights ... shall be considered if they:
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with cases which have been settled by these states involved in accordance with the
principles of the Charter of the ljnited Nations, or the Charter of the Organisation of
African Unity or the provisions of the present Charter. The Commission has not come
across any indication or evidence that the present Communication has been settled
before any other international forum. Accordingly, the Commission finds that the
requirement of Article 56 (7) of the African Charter has been fulfilled.
Decision of the Commission on Admissibility
11