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African Commission on Human and Peoples' Rights v Republic of Kenya (Application No. 006-2012)

African Court on Human and Peoples' Rights · [2019] AfCHPR 22 · 2019 Applications Dismissed AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Applications for intervention in ongoing reparations proceedings following judgment on merits
Decision
Applications for intervention dismissed as inadmissible

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

The African Court on Human and Peoples' Rights held that neither the Protocol nor the Rules provide a mechanism permitting third parties who are not State parties to intervene in ongoing proceedings. Even where States are permitted to intervene, this must be done before the close of pleadings. The Applications were filed one year and eleven months after the judgment on merits and six years and eight months after the case was originally filed, with no explanation for the delay. The Court declared the Applications inadmissible.

Outcome

Applications for intervention dismissed as inadmissible

Facts

On 26 May 2017, the African Court delivered judgment on merits in a case filed by the African Commission on Human and Peoples' Rights against Kenya concerning violations of the rights of the Ogiek Community of the Greater Mau Forest. The Court reserved determination on reparations. On 16 April 2019, two groups of individuals filed Applications seeking to intervene: Wilson Barngetuny Koimet and 119 others, and Peter Kibiegon Rono and 1300 others. The Applicants claimed to be registered owners of land within the Greater Mau Forest Complex since 1958 and argued that the Court's judgment would affect their interests as landowners. They alleged that members of the Ogiek Community had misled the Court and that some Ogiek had sold land to non-Ogiek including the intended intervenors. The Applicants sought to join the proceedings to protect their rights before the Court issued its judgment on reparations.

Issues

  1. Whether third-party individuals may intervene in ongoing proceedings before the African Court on Human and Peoples' Rights after judgment on merits has been delivered.
  2. Whether the Protocol and Rules of the African Court permit intervention by non-State parties.
  3. Whether the Applications for intervention were filed within the prescribed time limits.

Orders

  • Applications declared inadmissible.
  • Each party to bear its own costs.

Rules and key headnotes

Civil Procedure — Intervention — Standing of Non-State Parties
Neither the Protocol to the African Charter on Human and Peoples' Rights on the Establishment of an African Court on Human and Peoples' Rights nor the Rules of Court provide a mechanism permitting a third party which is not a State party to intervene in ongoing proceedings before the African Court.
Civil Procedure — Intervention — Time Limits for State Intervention
Where States are permitted to intervene in ongoing proceedings before the African Court, such intervention must be filed as soon as possible and in any case before the closure of written proceedings.
Civil Procedure — Intervention — Delay and Explanation
An application for intervention filed one year and eleven months after judgment on merits and six years and eight months after the original case was filed, without any explanation for the delay, will be dismissed as inadmissible where the litigation has generated media attention and its subsistence can be assumed to be common knowledge in the areas where the applicants reside.

Full judgment

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The original judgment as reported. Read the original PDF before relying on any passage.

African Commission on Human and Peoples' Rights v Republic of Kenya (Application No. 006-2012) [2019] AfCHPR 22 (4 July 2019)
Source: this page presents Wakilii’s issue analysis and metadata for a publicly reported Ugandan judgment. Any AI-generated summary is marked as such. Judgment text is sourced from the Uganda Legal Information Institute (ulii.org). Wakilii is not affiliated with ULII.