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Modise v Botswana (Communication 97 of 1993)

African Commission on Human and Peoples' Rights · Modise v Botswana (Communication 97 of 1993) [1993] ACHPR 6 (3 March 1993) · 1993 Application Dismissed AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Communication to the African Commission on Human and Peoples' Rights alleging denial of nationality
Decision
Communication not admitted for failure to exhaust local remedies; author directed to pursue domestic remedies

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

The African Commission on Human and Peoples' Rights decided that the communication concerning denial of nationality did not satisfy the requirement of exhaustion of local remedies under Article 56 of the African Charter. The Commission directed the author to exhaust local remedies and advised him to seek assistance from the Botswana Centre for Human Rights.

Outcome

Communication not admitted for failure to exhaust local remedies; author directed to pursue domestic remedies

Facts

John K. Modise filed a communication with the African Commission on Human and Peoples' Rights alleging denial of nationality by Botswana. The communication was dated 3 March 1993 and assigned Communication Number 97/93. The Commission considered the admissibility of the communication under the requirements of the African Charter on Human and Peoples' Rights.

Issues

  1. Whether the communication satisfied the requirement of exhaustion of local remedies under Article 56 of the African Charter on Human and Peoples' Rights.

Orders

  • Communication author to be advised of the need for exhaustion of local remedies as required by Article 56 of the Charter.
  • Communication author to be advised to contact the Botswana Centre for Human Rights for assistance.

Rules and key headnotes

Human Rights — African Charter — Admissibility — Exhaustion of Local Remedies
A communication to the African Commission on Human and Peoples' Rights must satisfy the requirement of exhaustion of local remedies under Article 56 of the African Charter on Human and Peoples' Rights before it can be admitted for consideration on the merits.

Legislation cited (2)

  • African Charter on Human and Peoples' Rights Article 56
  • African Charter on Human and Peoples' Rights Article 56(5)

Full judgment

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

Modise v Botswana (Communication 97 of 1993) [1993] ACHPR 6 (3 March 1993)
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.