Wakilii

Mustafa v Republic of Malawi (Application No. 008-2023)

African Court on Human and Peoples' Rights · [2024] AfCHPR 38 · 2024 Application Dismissed AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Application for provisional measures pending determination of main application alleging violation of fair trial rights in inheritance proceedings
Decision
Request for provisional measures dismissed; main application to proceed to determination on merits

Observed later treatment

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Holding

The African Court on Human and Peoples' Rights held that it has prima facie jurisdiction but dismissed the request for provisional measures. While the conditions of urgency and extreme gravity were met, the applicant failed to demonstrate with evidence that she would suffer irreparable harm if the Supreme Court of Appeal's decision was not stayed, as she provided no proof that the properties would be sold and any compensation would be the responsibility of the Respondent State, not the decree holder.

Outcome

Request for provisional measures dismissed; main application to proceed to determination on merits

Facts

Flora Mustafa, the third widow of the late Seleman Mustafa, was evicted from matrimonial property SAL 176 and business property SAL 177 by the deceased's second wife, Emily Mustafa. The applicant filed a complaint with the District Commissioner and claimed to have found a will bequeathing the properties to all children equally. Emily Mustafa filed a case at the High Court claiming the deceased died intestate and that she was sole owner of the properties through joint acquisition. The High Court held the deceased died intestate and appointed an administrator. On appeal, the Supreme Court of Appeal agreed the deceased died intestate but reversed the administrator appointment, holding that Emily Mustafa became sole owner of properties SAL 176 and 177 through survivorship as joint owner. The applicant's application for review was dismissed by the Supreme Court on 14 July 2021 without reasons being provided. The applicant then filed an application before the African Court alleging violation of her right to a fair trial.

Issues

  1. Whether the Court has prima facie jurisdiction to hear the request for provisional measures.
  2. Whether the conditions of extreme gravity and urgency are met to warrant the grant of provisional measures.
  3. Whether the applicant will suffer irreparable harm if the decision of the Supreme Court of Appeal is not stayed pending determination of the main application.

Orders

  • The Court has prima facie jurisdiction.
  • The request for provisional measures is dismissed.

Rules and key headnotes

Provisional Measures — Prima Facie Jurisdiction — Standard of Review
With respect to provisional measures, the Court need not satisfy itself that it has jurisdiction on the merits of the case, only that it has prima facie jurisdiction.
Provisional Measures — Requirements — Cumulative Nature
The requirements of urgency or extreme gravity and irreparable harm are cumulative, so that if one of them is lacking, the provisional measures requested cannot be ordered.
Provisional Measures — Irreparable Harm — Burden of Proof
An applicant seeking provisional measures must demonstrate with evidence that irreparable harm will occur, such as by providing proof of imminent sale through notices of sale, advertisements, or auction notices; mere assertion that property might be sold is insufficient.
Provisional Measures — Irreparable Harm — Compensation by State
Where any compensation due to an applicant would be made by the respondent State and not by a private party, the financial status of the private party is immaterial to the implementation of any decision on the main application and does not establish irreparable harm.

Cases cited (3)

  • Komi Koutche v Republic of Benin (Application No. 003/2019)
  • Houngue Éric Noudehouenou v Republic of Benin (Application No. 04/2020)
  • Ajavon Sebastien v Republic of Benin (Application No. 062/2019)

Full judgment

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

Mustafa v Republic of Malawi (Application No. 008-2023) [2024] AfCHPR 38 (18 March 2024)
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.