Docusign Envelope ID: A39DAFC4-4CAACRP8K
African Commission on
Human and Peoples' Rights
Human Rights our
Collective Respons1bil1ty
DECISION OF THE AFRICAN COMMISSION ON
HUMAN AND PEOPLES' RIGHTS ON
ADMISSIBILITY
COMMUNICATION 786/22
MASELINA MATHABELA (REPRESENTED BY ADV.
SHADRACK TEBEILE)
REPUBLIC OF SOUTH AFRICA
Adopted by the
African Commission on Human and Peoples •Riglua
During the 83rd Ordinary Session, held in Banjul, from 2 to 22 May 2025,
Banjul, 'The Gambia
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Human Rights our
Collective Responsibility
Human and Peoples' Rights
DECISION OF THE AFRICAN COMMISSION ON HUMAN AND
PEOPLES' RIGHTS ON ADMISSIBILITY
COMMUNICATION 786/22
MASELINA MATHABELA (REPRESENTED BY ADV.
SHADRACK TEBEILE) V. REPUBLIC OF SOUTH AFRICA
SUMMARY OF THE COMPLAINT
1. The Secretariat of the African Commission on Human and Peoples' Rights (the
Secretariat) received a Complaint on 16 February 2022 from Maselina
Mathabela (the Complainant), represented by Adv. Shadrack Tebeile, against
the Republic of South Africa (the Respondent State), a State Party to the African
Charter on Human and Peoples' Rights (the African Charter).
2. The Complainant alleges that she was born on 26 April 2000 in Springs,
Gauteng Province, South Africa, and has lived in the country her entire life. Even
so, she added that she is undocumented due to her parents' Mozambican
nationality and their inability to provide the necessary documentation for her to
acquire a South African identity card.
3. The Complainant further alleges that despite having a clinic card issued at her
birth, she has been unable to obtain an official birth certificate or identity
document. Additionally, her immunization card incorrectly lists her name as
"Marselina Mathebula" instead of "Maselina Mathabela."
4. It is alleged that in 2017, the Complainant approached the Department of Home
Affairs for an identity document but was informed that she would need to provide
documentation from her undocumented parents, who had already returned to
Mozambique.
5. The Complainant alleges further that this situation has resulted in significant
barriers to her accessing education, employment, and other vital services. She
alleged that in 2018, after completing Grade 12-the final year of se~~~~
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pursue higher education due to the lack of a valid identity docu . f'f
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6. The Complainant further alleges that, in November 2021 , she filed an urgent
application before the High Court of South Africa (Mpumalanga Division)
seeking an order compelling the Department of Home Affairs to issue her with
an identity document. The application was struck off the roll on the ground of
lack of urgency, and the Court did not address the substantive merits of the
claim. 1
7. Subsequently, the Complainant filed an application for direct access to the
Constitutional Court of South Africa, again raising the urgency of her
predicament. On 6 December 2021 , the Constitutional Court dismissed the
application for direct access, holding that it was not in the interests of justice to
hear the case at that time, and expressly indicating that there was no reason
the applicant could not pursue her proceedings in the High Court. 2
8. The Complainant avers that her inability to obtain identification documents,
despite meeting the criteria set forth in South Africa's Citizenship Act,
constitutes a violation of several rights guaranteed by the African Charter.
ARTICLES ALLEGED TO HAVE BEEN VIOLATED
9. The Complainant alleges violations of Articles 1, 2, 3, 4, 5, 6, 7(1 )(a), 12(2), 13,
17(1 ), and 22(1) of the African Charter on Human and Peoples' Rights by the
Respondent State.
PRAYERS
10. The Complainant prays that the Commission:
(a) Declare that the Respondent State has violated the Complainant's rights
under Articles 1, 2, 3, 4, 5, 6, 7(1)(a), 12(2), 13, 17(1), and 22(1) of the
African Charter on Human and Peoples' Rights.
(b)
Order that the Complainant be recognized as a South African citizen by
birth in terms of Section 2(2)(a) and (b) of the South African Citizenship
Act 88 of 1995.
(c)
Order that the Complainant be granted South African citizenship in terms
of Section 4(3)(a) and (b) of the South African Citizenship Act 88 of 1995.
(d)
Direct the Respondent State to register the Complainant's birth, enter her
details into the South African population register, and a ::l~!:!;1:Jt:i:t:~ Uth
African identity number.
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see annexure "FA16," H igh Court Order; also para. 18, Affidav it
2 see annexure "FA17," ibid
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(e)
Order that the Respondent State issue the Complainant with a birth
certificate and identity document within ten (10) days from the date of the
order.
(f)
Order the Respondent State to compensate the Complainant for legal
costs incurred in the High Court and Constitutional Court of South Africa,
including the costs of two counsel in both courts.
(g)
Order the Respondent State to pay the Complainant compensation in the
amount of R2 ,000,000.00 (Two Million South African Rands) within three
(3) months from the date of the order.
(h)
Grant any further orders the Commission deems fit in the circumstances.
PROCEDURE
11 . The Secretariat of the African Commission on Human and Peoples' Rights (the
Secretariat) received the Complaint from Maselina Mathabela (the
Complainant), represented by Advocate Shadrack Tebeile, on 16 February
2022.
12. On 13 June 2022, the Commission considered the Complaint and decided to
be seized of the matter in accordance with Rule 115(5) of its Rules of
Procedure, 2020. The Secretariat subsequently notified both parties of this
decision by letter and Note Verbale.
13. In the same correspondence, the Respondent State was informed of its
obligation to submit its arguments and evidence on both admissibility and
merits within sixty (60) days of notification, pursuant to Rule 116(1 ) of the Rules
of Procedure, 2020. The Secretariat also communicated the Commission's
decision to dismiss the Complainant's request for Provisional Measures, noting
that the Complainant had failed to demonstrate a risk of irreparable harm and
that granting the measures sought-namely, the issuance of a temporary
South African birth certificate and identity number-would pre-empt the
outcome of the proceedings on the merits.
14. On 21 June 2022, the Respondent State addressed a Note Verbale to the
Secretariat requesting the complete set of annexures, noting that certain
attachments to the Complaint were missing. On the same day, the Secretariat
acknowledged this request and transmitted the complete set of missing
documents to the Respondent.
15. On 26 April 2023, the Respondent State submitted a formal request for an
extension of thirty (30) days to file its observations on admissibility
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documentation. By letter dated the same day, the Secretaria I ra
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requested extension, allowing the Respondent until 6 June 2023 to submit its
observations.
16. On 26 May 2023, the Secretariat acknowledged receipt of the Respondent
State's submission on admissibility. However, it observed that the submission
did not include arguments on the merits. The Secretariat accordingly issued a
Note Verbale granting the Respondent a further thirty (30) days to submit its
observations on the merits.
17. On 19 June 2023, the Respondent State addressed a communication to the
Secretariat requesting an oral hearing on admissibility and merits, or
admissibility alone, so as to clarify the applicable domestic legal framework.
This request was transmitted to the Bureau of the Commission for
consideration in accordance with Rule 102(3) of the Rules of Procedure, 2020,
and was never granted .
18. On the same date, 19 June 2023, the Secretariat notified the Respondent State
that its observations on admissibility had been transmitted to the Complainant
for rejoinder within thirty (30) days, pursuant to Rule 116(2) of the
Commission's Rules of Procedure. The Complainant never filed a rejoinder.
PARTIES' SUBMISSIONS ON ADMISSIBILITY
Complainant's Submission
19. The Complainant submits that the present Communication satisfies all the
admissibility requirements set out under Article 56 of the African Charter on
Human and Peoples' Rights.
20. In compliance with Article 56(1 ), the Complainant avers that her identity is fully
disclosed. She states that she is an adult female, born on 26 April 2000 in
Springs, Gauteng Province, Republic of South Africa, and has resided in South
Africa her entire life. The Complainant further attaches a clinic card and
documentation affirming her place of birth to support her assertion of identity
and victim status within the meaning of the Charter. 3
21. With respect to Article 56(2), the Complainant contends that the Communication
is compatible with the Charter and the Constitutive Act of the African Union. She
submits that the rights alleged to have been violated are protected under the
African Charter and that the relief sought does not challenge the soverei~~)f::::~
territorial integrity of the Respondent State. The Complainant mainta· " ~ ~~Eth~:~1110 .o~
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Communication raises legal claims of a human rights nature and
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22. With regard to Article 56(3), the Complainant affirms that the language of the
Communication is respectful and devoid of any disparaging or insulting
expressions. She stresses that the pleadings are formulated in the tone and
style of a legal petition and do not improperly attack the institutions of the
Respondent State or the African Union.5
23. In relation to Article 56(4), the Complainant submits that the Communication is
not based exclusively on information disseminated through the media. Rather,
she relies upon first-hand testimony and verifiable documentation, including a
clinic card, official correspondence, and the record of domestic judicial
proceedings. The Complainant further states that the facts alleged are
supported by her affidavit and by the annexed materials submitted to the
Commission.6
24. As to the requirement of exhaustion of local remedies under Article 56(5), the
Complainant submits that she approached the High Court of South Africa,
seeking urgent relief in relation to her lack of identity documentation. The High
Court, however, struck out her application on 18 November 2021 for lack of
urgency.
25. Subsequently, she applied to the Constitutional Court of South Africa, which
dismissed her application on 6 December 2021 . The Complainant contends that
these steps constituted an exhaustion of available and effective domestic
remedies. She appends copies of the relevant High Court and Constitutional
Court processes and decisions to her affidavit. 7
26. The Complainant further argues that, in any event, the domestic remedies
available to her were ineffective and incapable of providing adequate redress.
She submits that her repeated efforts over a prolonged period to regularize her
status with the Department of Home Affairs proved unsuccessful,
notwithstanding her eligibility for documentation. The Complainant further
contends that the legal avenues she pursued failed to provide timely and
effective relief, thereby rendering the available remedies inadequate in the
circumstances of her case. She particularly notes that the lack of documentation
precluded her from enrolling in university, and that the harm occasioned was of
a continuing and urgent nature, which domestic processes were incapable of
remedying. 8
27. Concerning Article 56(6), the Complainant avers that the Communication was
submitted within a reasonable time following the Constitutional Court's dismissal
5ibid
See, Complainant's Affidavit for Evidence on Admissibility and Merits, paras 10-13 and supporting
annexes.
7
ibid, paras 17-25; Submissions on Admissibility and Merits, paras 23-28; see anne
Order (18 November 2021) and Constitutional Court application (6 December 2021).
8 Submissions on Admissibility and Merits, paras 25-28.
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of her application on 6 December 2021. The Communication was filed before
the African Commission on 16 February 2022, a period of approximately two
months. The Complainant contends that this interval is reasonable in the
circumstances and does not amount to undue delay, particularly given the
seriousness of the violations alleged. 9
28. Finally, with regard to Article 56(7), the Complainant affirms that the matter has
not been submitted to any other international mechanism of settlement and that
no parallel proceedings are pending before any other international or regional
forum. The Complainant, therefore, maintains that the present Communication
is not inadmissible on grounds of duplication. 10
Respondent's State Submission on Admissibility
29. The Respondent State, in its submissions, argued that the Communication fails
to satisfy the admissibility requirements set out under Article 56 of the African
Charter. It primarily contests the admissibility of the Communication on the basis
of Article 56(5), alleging that the Complainant failed to exhaust domestic
remedies, and Article 56(6), contending that the Communication was not
submitted within a reasonable time after exhaustion of those remedies.
30. The Respondent did not object Articles 56(1) to (4) of the Charter. It did not
contest the disclosure of the Complainant's identity, nor argue that the
Communication was incompatible with the African Charter or the Constitutive
Act of the African Union. Furthermore, it did not allege that the Communication
employed disparaging or insulting language, nor did it assert that the claims
were based exclusively on media reports .
31. In regard to Article 56(5) of the Charter, which requires that local remedies be
exhausted before a communication may be submitted to the Commission. The
Respondent submitted that the Complainant failed to pursue or exhaust
available and effective domestic remedies under South African law. 11 It
emphasized that the High Court's dismissal of the Complainant's application on
18 November 2021 was procedural and did not determine the merits of her claim
to documentation or legal status.12 According to the Respondent, the
Complainant voluntarily withdrew her application to the Constitutional Court on
6 December 2021 before that court could render a decision, further interrupting
the chain of available judicial remedies. 13
32. The Respondent also asserted that South African law affords multiple remedies
through appeal and judicial review, including the possibility of review under the
4-vo
9
Complainant's Affidavit, para 29; Submissions on Admissibility and Merits, pa
10 Complainant's Affidav it, para 31; Submissions on Admissibility and Merits, p
11 Respondent's O bservations on Admissibility, paras 21, 27.
12 Ibid., paras 22-23.
13 Ibid., p aras 25-26.
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Promotion of Administrative Justice Act (PAJA), which the Complainant never
invoked. 14 It argued that failure to pursue these remedies, particularly the failure
to file a PAJA review or appeal to the Supreme Court of Appeal or to seek
reinstatement of the withdrawn Constitutional Court application, amounts to
non-exhaustion.15 Relying on the jurisprudence of the Commission in Rencontre
Africaine pour la Defense des Droits de /'Homme v Zambia, the Respondent
contended that dissatisfaction with domestic outcomes or premature
disengagement does not absolve a party of the obligation to exhaust remedies
that remain legally and practically available.16
33. On Article 56(6), the Respondent State further submitted that the
Communication does not comply with the requirement, which mandates that a
communication be submitted "within a reasonable period from the time local
remedies are exhausted ." It contended that although the Complainant initiated
proceedings in the domestic courts, her application to the Constitutional Court
was dismissed on 6 December 2021 , and thereafter she took no further legal
steps before filing the Communication on 16 February 2022.17 The Respondent
acknowledged that the period between the final domestic proceeding and the
filing was approximately two months, but argued that no justification was
provided for the timing of the submission, particularly given the urgency and
long-standing nature of the alleged violation.
34. The Respondent emphasized that the Complainant was legally represented
during the domestic proceedings and in the filing of the Communication, and
thus was fully capable of acting with diligence.18 It is submitted that the
Commission has consistently held that timeliness must be assessed in light of
each case's specific circumstances and that delays in submission should be
viewed with greater scrutiny in matters alleging long-term administrative
injustices or inaction , such as denial of documentation.19 The Respondent also
cited the Commission's decision in A/oys Bizimungu v Rwanda to support the
view that delay without explanation or demonstrated impediment may render a
communication inadmissible under Article 56(6).20
35. In light of these consideration s, the Respondent requested that the Commission
find the Communication inadmissible for failure to comply with the time limitation
imposed by Article 56(6), arguing that no exceptional or extenuating factors
14 Ibid., paras 28-30.
1s 1bid., paras 31, 45- 47.
16
Ibid., para 36, citing Communication 71/92 - Rencontre Africaine pour la Defense de
Z ambia (2000) AHRLR 321 (ACHPR 1995) para 10.
17 Respondent's Observations on Admissibility, 18 April 2023, paras 52-53.
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18 Ibid., para 56.
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Ibid., para 57, citing A loys Bizimungu v Rwanda, Communication 336/ 07 (ACI
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were provided to justify the Complainant's delay in approaching the
Commission. 21
Commission's Analysis on Admissibility
36. It is a condition that any communication submitted in terms of Article 55 must
satisfy the seven requirements in Article 56 to be declared admissible.
Regarding this, the Commission reiterates its position in FIDH & Others vs
Senegal22 and remains guided by the principle that the conditions outlined in
Article 56 are cumulative and should all be adequately fulfilled for a
communication submitted in conformity with the terms of Article 55. The
Commission will, therefore, consider the complaints in accordance with these
requirements, taking into account the relevant provisions, the submissions of
both parties, the Commission's analysis, and its decisions.
Article 56(1 ): Identity of the Complainant
37.Article 56(1) of the African Charter requires that a communication indicate the
identity of its author, even where anonymity is requested.
38. In Spilg and Mack & DITSHWANELO (on behalf of Lehlohonolo Bernard
Kobedi) v Botswana, 23 the Commission clarified that the identity requirement
is intended to ensure the Commission can verify the complainant's standing
and interest in the matter and maintain communication throughout the
proceedings. This is essential for procedural fairness and administrative
coordination, and the Commission does not need to impose an inflexible
standard where the complainant is duly represented or publicly identified.
39. In the present Communication, the Complainant has clearly disclosed her
identity, date and place of birth, and legal representation. 24The Respondent
State has not challenged the identity or standing of the Complainant at any
stage. Accordingly, the Commission finds that the requirement under Article
56(1) has been met.
Article 56(2): Compatibility with the Charter and the Constitutive Act
40. Article 56(2) requires that communications be compatible with the African
Charter or the Constitutive Act of the African Union. This requirement has been
interpreted by the Commission to include a fourfold competence test-ratione
personae, ratione materiae, ratione loci, and ratione temporis-as clarified in
Jean-Pierre Bemba Gombo v Democratic Republic of Congo.25
21 Ibid., paras 59-60
22 Communication 292/ 04 para. 34
23 Communication No. 277 / 03), para. 88.
24 This information is evident in paragraphs 1 and 2 of the Communication an
Complainant's Affidavit on Evidence in Support of Admissibility and Merits.
25 Communication No. 204/ 97, paras. 24-26.
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41 . In this communication, the Complainant alleges violations of Articles 1, 2, 3, 5,
6, 12, 14, and 18 of the Charter relating to equality, dignity, liberty, residence,
property, and protection of the family. These allegations fall squarely within the
material jurisdiction of the Charter (ratione materiae). The Respondent State,
the Republic of South Africa, is a State Party to the African Charter, having
ratified it on 9 July 1996 (ratione personae). The alleged violations occurred
between 2012 and 2022, after the Charter's ratification (ratione temporis), and
are alleged to have occurred within the territory of South Africa (ratione loci).
42. Moreover, the Commission notes that the nature of the remedies sought,
relating to legal recognition, documentation, and access to fundamental
services, is compatible with the object and purpose of the African Charter and
the Constitutive Act of the African Union. The Commission accordingly finds
that the requirement under Article 56(2) is fulfilled.
Article 56(3): Language Requirement
43.Article 56(3) requires that a communication must not contain disparaging or
insulting language directed at the State or the African Union.
44. In Zimbabwe Lawyers for Human Rights and Associated Newspapers of
Zimbabwe v Zimbabwe, the Commission held that this condition is only
violated where the language used seeks to impair the dignity or integrity of
State institutions intentionally, or is calculated to undermine public confidence
in the administration of justice. 26
45. Upon reviewing the Complainant's submissions, including the Urgent
Communication and the Written Submissions on Admissibility and Merits, the
Commission finds no language that can be construed as inflammatory or
intentionally disrespectful. The Respondent State has not alleged otherwise.
The Commission therefore finds that the requirement under Article 56(3) has
been complied with.
Article 56(4): Not Based Exclusively on Media Reports
46.Article 56(4) prohibits communications that rely exclusively on media sources.
This does not preclude all media use, but the Commission has emphasized
that factual allegations must be substantiated by credible and verifiable
evidence.
47. In Jawara v The Gambia, the Commission explained that the test is whether a
communication is based on substantiated facts, not simply whether it refers to
news outlets.27 Similarly, in Ahmed Ismael and 528 Others v Egypt, the
26
27
Communication No. 284/ 03, paras. 75-77.
Jawara v The Gambia, Communications Nos. 147/ 95 and 149/ 96, paras.
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Commission held that complainants may refer to media sources if the
information is credible and corroborated.28
48. In this case, the Complainant relies on official correspondence with domestic
institutions, medical and school records, court pleadings, and judicial
decisions.29 The Respondent did not challenge the authenticity or sufficiency
of these sources. Thus, the Commission finds that the communication is not
based exclusively on media reports and satisfies the requirement of Article
56(4).
Article 56(5): Exhaustion of Local Remedies
49.Article 56(5) of the African Charter stipulates that a communication must be
submitted "after the exhaustion of local remedies, if any, unless it is obvious that
this procedure is unduly prolonged." The Commission has consistently held that
this condition requires remedies to be available, effective, and sufficient. A
remedy is available if the complainant can pursue it without impediment,
effective if it offers a reasonable prospect of success, and sufficient if capable
of providing redress. 30
50. The Complainant submits that she attempted to exhaust domestic remedies by
filing an urgent application before the Mpumalanga Division of the High Court of
South Africa , which was struck off the roll on the grounds of lack of urgency. 31
She then filed an application for direct access to the Constitutional Court, which
was also dismissed without consideration of the merits.32 The Complainant
maintains that this sequence of events exhausted available domestic remedies
or demonstrates that effective remedies were unavailable, as neither court
addressed the substance of the complaint. 33
51. In response , the Respondent State argues that the Complainant failed to
exhaust local remedies, contending that she could have re-enrolled the matter
on the ordinary court roll or sought alternative remedies such as review
proceedings or internal administrative redress mechanisms.34The State further
submits that the High Court's dismissal was procedural and did not preclude the
Complainant from pursuing a merits-based determination. 35
52. The Commission recalls its decision in Sir Dawda K. Jawara v The Gambia,
where it held that "remedies, the availability of which is not evident, cannot be
28
Communication No. 768/ 21, para. 103.
See paragraphs 17-27 of the Com plainant's Affidavit, and in paragraphs 10- 24 of the Wri tten
Submissions on Admissibility.
30
Jawara v The Gambia (2000) AHRLR 107 (ACHPR 2000), Communications Nos 147/95 and 149/96,
paras 31-33.
31
Complainant's Submissions on Admissibility and Merits, paras 17- 21.
32
Complainant's Affidavit on Evidence, paras 18-20
33
Ibid, paras 20-23; see also Complainant's Submissions, paras 28-29.
34
Responden t's Observations on Ad missibility, paras 23-27.
35 Ibid, paras 29- 31
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invoked by the State to the detriment of the Complainant."36 Similarly, in Monim
Elgak, Osman Hummeida and Amir Su/iman v Sudan , the Commission found
that remedies that are procedurally obstructed or inaccessible in practice do not
satisfy the exhaustion requirement. 37
53. In the present case, the Commission notes that the High Court's striking off of
the matter on urgency grounds did not preclude the Complainant from reenrolling the application through ordinary procedures. 38 The Complainant never
contended that re-enrolment was legally barred or practically impossible, but
rather that she perceived further proceedings to be futile. However, the
Commission reiterates that procedural dismissals do not constitute exhaustion
of local remedies unless the complainant demonstrates that further steps would
have been unavailable or ineffective.
54. Additionally, the Commission observes that the Complainant did not challenge
the High Court decision through appeal or review, nor did she pursue relief
through the ordinary court roll, notwithstanding the availability of these avenues
under South African law. 39The Commission has previously held in Human
Rights Council and Others v Ethiopia that "where a complaint is dismissed on
procedural grounds and the complainant fails to take further steps to access a
substantive hearing , local remedies cannot be said to have been exhausted."40
55. In light of the above, and considering that the Complainant failed to pursue the
matter substantively following procedural dismissal, the Commission finds that
the requirement under Article 56(5) has not been met
Article 56(6): Timeliness of the Communication
56. Article 56(6) requires that communications "are submitted within a reasonable
period from the time local remedies are exhausted or from the date the
Commission is seized of the matter."
57. Now that Article 56(5) has not been met, the Commission remains guided by
its position in The Promoting Justice for Women and Children (PROJUST
NGO) vs. the Democratic Republic of Congo,25 also accepted in the Human
Rights Defenders Network- Sierra Leone (HRDN-SL) and West African Human
Rights Defenders Network (WAHRDN) vs. The Republic of Sierra Leone41 that
where Article 56(5) has not been complied with, the Commission does not
need to make a conclusive determination on Article 56(6).
36 Jawara v The Gambia, supra note, para 32.
37
UMA
M onim Elgak, Osman Hwnmeida and Amir Suli111a11v S11dan, Communication No 379~
88-90
38
Res pondent's Observations, paras 24, 31
39 ibid, paras 32-33
4
°Communication No 428/ 12, para 90
41
Communication 648/ 16, para 53
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The African Commission on Human
31 Bijilo Annex Layout,
West Coast Region- Gambia
Pho ne: (220) 230 4361 Fax: (220) 441 05 04
Fm;:1il · ::u1-h:::ini11lfm~frir.:=.-1ininn nrn
Art.56(7): The Matter Not Settled by Another International Procedure
58. Article 56(7) stipulates that a communication must not d eal with cases which
have been settled by those States involved in accordance with the principles
of the Charter of the United Nations, or the Charter of the Organization of
African Unity, or the provisions of the present Charter.
59. Interrogating the parties' submissions in the present communication, the
Complainants submitted that the present Communication has not been
considered or settled by any other international human rights body. The
Respondent State does not contest this submission. The Commission finds that
the requirement under Article 56(7) is met.
DECISION
60. In view of the foregoing, the Commission finds that the communication does
not satisfy the admissibility criteria set out under Article 56(5) of the Charter.
61. Consequently,
(i)
declares the communication NOT ADMISSIBLE.
(ii)
Decides to notify the parties of its d ecision in accord
118(4) of its Rules of Procedure.
Done during the 83rd Ordinary Session held in Banjul, the Garn
May 2025.
121 Page
t~c)
The African Commission on Human and Peoples' Rights
31 Bijilo Annex Layout, Kombe North District,
West Coast Region Gambia
Phone: (220) 230 4361 Fax: (220) 441 05 04
Email: au-baniul®africa-union.oro