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Union Nationale De Liberation De Cabinda v Angola (Communication 24 of 1989)

African Commission on Human and Peoples' Rights · [1989] ACHPR 2 · 1989 Communication Dismissed AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Communication to African Commission alleging denial of self-determination
Decision
Communication dismissed for lack of jurisdiction

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

The African Commission declared the communication inadmissible on the ground that it was directed against Angola, a state that was not party to the African Charter on Human and Peoples' Rights at the time. Under article 101 of the Rules of Procedure, the Commission lacks jurisdiction to consider communications against non-state parties to the Charter.

Outcome

Communication dismissed for lack of jurisdiction

Facts

On 2 April 1988, Union Nationale De Liberation De Cabinda filed a communication with the African Commission alleging denial of self-determination against Angola. At the time the communication was filed and considered, Angola was not a party to the African Charter on Human and Peoples' Rights. The Commission considered the communication at its fifth ordinary session held from 3 to 14 April 1989.

Issues

  1. Whether the African Commission has jurisdiction to consider a communication directed against a state that is not party to the African Charter on Human and Peoples' Rights.

Orders

  • Communication declared inadmissible under article 101 of the Rules of Procedure.

Rules and key headnotes

Human Rights — Jurisdiction of African Commission — Ratione Personae — Communications Against Non-State Parties
The African Commission on Human and Peoples' Rights lacks jurisdiction to consider communications directed against states that are not party to the African Charter on Human and Peoples' Rights.

Legislation cited (2)

  • African Charter on Human and Peoples' Rights art.30
  • Rules of Procedure of the African Commission art.101

Full judgment

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

Union Nationale De Liberation De Cabinda v Angola (Communication 24 of 1989) [1989] ACHPR 2 (14 April 1989)
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.