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Uganda Judgment

African Commission on Human and Peoples Rights

Korvah v Liberia (Communication 1 of 1988) [1988] ACHPR 16 (26 October 1988)

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Professional case brief

Research organized from the available case record

Source document

01

Holding and result

The Commission found that the communication was not properly addressed to it but rather to the Liberian government, failing the procedural requirement for admissibility. Furthermore, the Commission determined that the five matters described in the communication did not amount to violations of human rights as defined under the African Charter. Consequently, the communication was declared inadmissible under Article 114 of the Rules of Procedure and Article 56 of the Charter.

Court disposition

communication declared inadmissible

Orders

  • The communication is declared inadmissible.

02

Material facts

Parties

Frederick Korvah

Applicant

Republic of Liberia

Respondent

03

Procedural history

  1. Posture

    Communication / Final Decision

04

Questions and positions

Legal issues

Party arguments

Applicant
The applicant alleged issues relating to the situation in Liberia, including corruption and immorality, and sought the Commission's intervention under the African Charter on Human and Peoples' Rights.
Respondent
The respondent did not submit arguments as the communication was not formally addressed to the Commission and was found inadmissible on procedural and substantive grounds.

05

Court’s reasoning

  1. 01

    Article 114 of the Rules of Procedure

    A communication must be properly addressed to the African Commission to be considered.

  2. 02

    Article 56 of the African Charter on Human and Peoples' Rights

    Only matters amounting to violations of human rights under the Charter are admissible.

06

Ratio, limits and disposition

Ratio decidendi

The Commission found that the communication was not properly addressed to it but rather to the Liberian government, failing the procedural requirement for admissibility. Furthermore, the Commission determined that the five matters described in the communication did not amount to violations of human rights as defined under the African Charter. Consequently, the communication was declared inadmissible under Article 114 of the Rules of Procedure and Article 56 of the Charter.

Court disposition

communication declared inadmissible

  • The communication is declared inadmissible.

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

[1988] ACHPR 16

AFRICAN COMMISSION ON HUMAN AND PEOPLES' RIGHTS Fourth Ordinary Session 17-26 October 1988

FEDERICK KORVAH v. LIBERIA

DECISION

Citation: Korvah v. Liber., Comm. 1/88, 7th ACHPR AAR Annex IX (1993-1994) Alt. Style of Cause: Frederick Korvah v. Liberia Publications: IHRDA, Compilation of Decisions on Communications of the African Commission On Human and Peoples' Rights Extracted from the Commission's Activity Reports 1994-2001, at 150 (2002); Documents of the African Commission on Human and Peoples' Rights, at 337 (Malcolm D. Evans & Rachel Murray eds., 2001); (2000) AHRLR 140 (ACHPR 1988)

COMMUNICATION ON THE SITUATION IN LIBERIA INCLUDING CORRUPTION, IMMORALITY, ETC (JULY 26, 1987)

FINAL DECISION

- [1] "The African Commission on Human and Peoples' Rights, established under article 30 of the African Charter on Human and Peoples' Rights; - [2] Meeting at its fourth ordinary session held from 17 26 October 1988; - [3] Considering that the communication is not addressed to the Commission but to the Liberian government; - [4] Considering further that the five matters described in this communication do not amount to violations of human rights under the provisions of the Charter; - [5] Declares the communication inadmissible". (Article 114 of the Rules of Procedure Article 56 of the Charter).

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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, Article 56

Legislation

Legislation referenced in the available case record.

Rules of Procedure of the African Commission on Human and Peoples' Rights, Article 114

Legislation

Legislation referenced in the available case record.

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