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Uganda Judgment

African Commission on Human and Peoples Rights

Houver v Morocco (Communication 41 of 1990) [1990] ACHPR 5 (28 April 1990)

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Professional case brief

Research organized from the available case record

Source document

01

Holding and result

The African Commission declared the communication inadmissible because Morocco, the respondent State, was not a party to the African Charter on Human and Peoples' Rights at the time of the complaint. The Commission's jurisdiction is limited to communications against States that have ratified the Charter. As such, the complaint could not be entertained under the Commission's rules, specifically Article 101 of the Rules of Procedure.

Court disposition

communication declared inadmissible

Orders

  • The communication is declared inadmissible under Article 101 of the Rules of Procedure.

02

Material facts

Parties

Andre Houver

Applicant

Morocco

Respondent

03

Procedural history

  1. Posture

    Communication / Admissibility

04

Questions and positions

Legal issues

Whether the communication is admissible against a State that is not a party to the African Charter on Human and Peoples' Rights.

Party arguments

Applicant
The applicant alleged political imprisonment and other wrongdoing by the respondent State, seeking redress under the African Charter on Human and Peoples' Rights.
Respondent
Morocco did not submit arguments, as the communication was dismissed on procedural grounds.

05

Court’s reasoning

  1. 01

    Article 101 of the Rules of Procedure of the African Commission on Human and Peoples' Rights

    A communication is inadmissible if it is directed against a State that is not a party to the African Charter on Human and Peoples' Rights.

06

Ratio, limits and disposition

Ratio decidendi

The African Commission declared the communication inadmissible because Morocco, the respondent State, was not a party to the African Charter on Human and Peoples' Rights at the time of the complaint. The Commission's jurisdiction is limited to communications against States that have ratified the Charter. As such, the complaint could not be entertained under the Commission's rules, specifically Article 101 of the Rules of Procedure.

Court disposition

communication declared inadmissible

  • The communication is declared inadmissible under Article 101 of the Rules of Procedure.

Source and reliance status

African Commission on Human and Peoples Rights

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Source document

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Judgment text

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Source document

African Commission on Human and Peoples Rights

Judgment

[1990] ACHPR 5

25 April 1990 Communication No. 41/90

AFRICAN COMMISSION ON HUMAN AND PEOPLES' RIGHTS Seventh Ordinary Session 18-28 April 1990

ANDRE HOUVER v. MOROCCO

DECISION

Citation: Houver v. Morocco, Comm. 41/90, 7th ACHPR AAR Annex IX (1993–1994) Publications: Documents of the African Commission on Human and Peoples' Rights, at 344 (Malcolm D. Evans & Rachel Murray eds., 2001)

COMMUNICATION ON ALLEGED POLITICAL IMPRISONMENT AND OTHER WRONG DOING, DATED, MARCH 28, 1990

- [1] The African Commission on Human and Peoples' Rights; established under Article 30 of the African Charter on Meeting at its Seventh Ordinary Session held from 18 to 28 April, 1990 in Banjul (The Gambia); - [2] Has taken the following decision: - [3] At its sitting on Wednesday 25 April 1990; - [4] Considering that the communication is directed against a State non-party to the African Charter; - [5] Declares the communication inadmissible. (Article 101 of the Rules of Procedure).

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Authorities

Authorities used by the court

Cases, legislation, regulations, and constitutional provisions identified in the available record.

African Charter on Human and Peoples' Rights

Legislation

Legislation referenced in the available case record.

Article 101 of the Rules of Procedure of the African Commission on Human and Peoples' Rights

Legislation

Legislation referenced in the available case record.

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