Bringing Human Rights off the Pitch: The absence of Accountability for abuses surrounding the 2022 FIFA World Cup in Qatar

By: Henry Smith, Junior Research Associate, PILPG-NL

In March 2021, during the qualifying matches for the 2022 Football World Cup organized by the Fédération Internationale de Football Association (FIFA), players of the national football teams of the Netherlands, Germany, Norway, and Denmark walked onto the fields in shirts with messages such as “human rights on and off the pitch”, and “football supports change”.  The on-field protests were aimed at the alleged human rights violations committed against migrants working on the construction of stadiums and facilities for the next World Cup in Qatar.

Both Qatar and FIFA have recently come under heavy criticism for not taking action against those allegations.  Although Qatar has adopted measures aimed at addressing the issue, it has failed to implement them, and migrant workers continue to report dire conditions.  

This article examines Qatar’s obligations under international human rights law and assesses whether victims can seek remedies before human rights institutions, or, alternatively, whether it would be possible to hold FIFA accountable.

The alleged violations

According to Amnesty International, since the beginning of the construction of facilities for the 2022 World Cup, workers from Bangladesh, India, and Nepal have been subjected to forced labor, received low and delayed salaries, and have lived in appalling conditions.  Workers were hired under the kafala system, in which their working visas were tied to their employers, and they would have to request permission to change jobs or leave Qatar.  Furthermore, migrants do not have the right to join trade unions or to go on strike.  Moreover, there are estimates that indicate that, in that period, more than six thousand migrant workers have died as a result of the precarious work conditions.

While Qatar has adopted significant reforms to its labor laws, including the abolishment of the kafala system, and the adoption of a basic minimum wage, a recent report by Human Rights Watch indicates that the violations have continued in practice. 

Human rights related to labor are protected by the International Covenant on Civil and Political Rights (ICCPR), and the International Covenant on Economic Social and Cultural Rights (ICESCR).  Article 8 of the ICCPR prohibits forced labor, and Article 22 provides the rights of association and of forming trade unions.  As for the ICESCR, according to Article 7, states should ensure fair wages, decent living standards, safe and healthy working conditions, and reasonable limitations of working hours.  Article 8 provides the rights to form trade unions and strike. 

Seeking remedies

Although Qatar became a party to the Covenants in 2018, it has not signed or ratified the Optional Protocol to either of them..  As a result, it has not consented to the jurisdiction of the United Nations Human Rights Committee or the United Nations Committee on Economic, Social and Cultural Rights, which are the monitoring mechanisms of these Conventions.  Consequently, the international human rights framework does not provide migrant workers with effective means for seeking remedies against Qatar for the human rights abuses they have been subjected to.

Migrant workers will also be unable to seek remediation from FIFA through international mechanisms.  The international human rights framework only creates obligations for states.  Although FIFA has included a commitment to respect “internationally recognized human rights'' in its Statute, as a non-state actor, it cannot be held responsible under international law.  Moreover, the international human rights framework applicable to businesses merely consists of guidelines and codes of conduct, such as the United Nations Guiding Principles on Business and Human Rights, which are not legally binding instruments. 

Alternatively, a possible avenue for seeking remediation from FIFA may be through the state in which it is domiciled: Switzerland.  In accordance with the nationality principle of jurisdiction, domestic courts have jurisdiction over cases where the perpetrator of a violation is a national of the state.  In fact, a claim was brought to a Swiss commercial court in Zurich in 2014 by a Bangladeshi worker.  According to the claimant, by awarding the World Cup to Qatar without compelling it to secure migrant worker’s rights, FIFA had knowingly put those people in danger, breaching Swiss law.  The claimant requested the court to order FIFA to press Qatari authorities to ensure the fundamental rights of migrant workers, to declare the unlawfulness of FIFA’s negligent conduct towards human rights, and to award a compensation of 4,000 US dollars to the victim.  The court held that the claims were too vague and failed to indicate exactly which of FIFA’s acts constituted human rights violations.  Consequently, the case was dismissed on admissibility grounds. 

As the court did not issue a decision on the merits of the case, other cases related to the abuses in the preparations for the World Cup can still be filed against FIFA.  However, the court noted in the decision that FIFA did not have the capacity to ensure the observance of human rights, as this is the responsibility of Qatar.  In effect, the Swiss court indicated that it would be very difficult for victims to claim remedies effectively from FIFA for the abuse they suffered while working in Qatar.

Concluding remarks

Under current circumstances, it is difficult to see how migrant workers could effectively request remedies for the human rights abuses suffered in the preparations for the 2022 World Cup in Qatar.  As long as Qatar does not consent to the jurisdiction of a human rights body, it cannot be held responsible for those abuses through an international mechanism.  And, as long as there is no international framework that imposes binding obligations on corporations, there is little reason to believe that FIFA could be held responsible for human rights violations.  Until then, it is likely that human rights will remain only “on the pitch”.

Gbagbo and Blé Goudé Acquittal: The ICC’s Standard of Review in “No Case to Answer” Applications

By: Adam DiSimine, Junior Research Associate, PILPG-NL

On March 31, 2021, the Appeals Chamber of the International Criminal Court (ICC) upheld the acquittal of Laurent Gbagbo and Charles Blé Goudé, finalizing their release from custody.  Mr. Gbagbo and Mr. Blé Goudé had previously been acquitted by Trial Chamber I of the ICC for crimes against humanity allegedly committed in Côte d'Ivoire in 2010 and 2011.  The Prosecutor had appealed the Trial Chamber’s decision on two grounds: (i) a failure to meet statutory requirements concerning the delivery of verdict and reasons and (ii) the standard of proof used when assessing evidence in “no case to answer” applications.  This blog post will take a close look at the second ground of appeal and examine the Appeals Chamber’s ruling on the appropriate standard of review when the ICC is deciding “no case to answer” applications.  It will begin with a brief look at the ICC’s prior treatment before examining both the majority opinion and the dissenting opinion of Judge Luz del Carmen Ibáñez Carranza in the Gbagbo and Blé Goudé appeal.

Prior Standards of Review

A “no case to answer” application allows an accused to request acquittal after the Prosecution has presented its case on the basis of insufficient evidence.  In the past, the ICC has been criticized for an inconsistent approach throughout its case law.  Part of the reason for this is that the Rome Statute of the International Criminal Court (Rome Statute) does not provide for an explicit standard of review in “no case to answer” applications.  As a result, the judges of the ICC are left to their own discretion when considering applications.  In the Ruto case, the Trial Chamber established that the standard of review only requires a determination of whether the court “could” convict an accused.  The Trial Chamber emphasized “could” and affirmed that the standard to be applied was not the same as that for conviction.  Conversely, some scholars have argued that by citing jurisprudence of the International Criminal Tribunal for the Former Yugoslavia (ICTY), the ICC also endorsed a standard of proof beyond a reasonable doubt.  Later, in the Gbagbo and Blé Goudé case, the Trial Chamber established that the standard of review would require the Prosecution to meet the requirements for conviction, as set out in Article 66 of the Rome Statute, requiring proof of guilt beyond reasonable doubt.   As a result of this seeming inconsistency, the ruling by the Appeals Chamber is a welcome clarification.

The Majority Opinion

In their lengthy decision on the appeal of the “no case to answer” decision, the Appeals Chamber affirmed the standard of review established by the Trial Chamber in the Gbagbo and Blé Goudé case.  The Appeals Chamber noted that the applicable test found in ICTY and national jurisprudence requires acquittal “where the evidence thus far presented is insufficient in law to sustain a conviction on one or more of the charges.”  The Appeals Chamber went on to note that the proper application of this test makes it “wholly appropriate and correct to articulate the standard of proof at the level of proof beyond reasonable doubt and nothing less.”  As a result, the Appeals Chamber cemented the higher standard of beyond reasonable doubt, which is necessary for conviction.  As noted by the Appeals Chamber, this standard is consistent with the tests of several national jurisdictions.  If the evidence presented by the Prosecution at the end of its case would not be sufficient to convict the accused, then a Trial Chamber may grant a “no case to answer” application and acquit the accused.  The decision of the Appeals Chamber was well reasoned and based on an extensive review of prior practices of other courts.  It opined not only on the applicable test to be applied but also on the standard for assessing the credibility and reliability of evidence, providing practical guidance to future judges. 

The Dissenting Opinion

The dissenting opinion of Judge Luz del Carmen Ibáñez Carranza provides novel ideas on this topic.  Most importantly, Judge Ibáñez Carranza rejects the appropriateness of “no case to answer” applications in their entirety.  In her opinion, the use of a “no case to answer” procedure is not established in the Rome Statute, “has no applicable rules of procedure or evidence [and] has completely disrupted the balance of the Rome Statute System” in the Gbagbo and Blé Goudé case.   Judge Ibáñez Carranza casts the Rome Statute System as a sui generis legal system and asserts the existence of “no case to answer” applications contravenes principles of fairness and due process.  A delicate balance of interests was carefully crafted by the States Parties and this case has allowed judges to disrupt that balance by developing a mechanism not envisioned by the Rome Statute System.  Her dissenting opinion demonstrates the ongoing debate and uncertainty within the ICC itself on the treatment of “no case to answer” applications.  It may also serve as a nudge to States Parties to clarify the appropriateness of “no case to answer” applications before the ICC. 

Conclusion

Ultimately, the decision of the Appeals Chamber, while not unanimous, will provide future Trial Chambers with guidance as they entertain “no case to answer” applications from accused persons who believe the Prosecutor has not presented sufficient evidence.  The decision of the Appeals Chamber in the Gbagbo and Blé Goudé case has affirmed the high standard the Prosecution must meet to successfully present a “no case to answer” application by the defense.  This is the most recent in a string of ICC decisions on this subject and provides a welcome degree of predictability in an uncertain area of international criminal law.

The U.K. Overseas Operations Bill

By: Katherine Grzadkowska, JUNIOR RESEARCH ASSOCIATE, PILPG-NL

On April 29, 2020, the Overseas Operations (Service Personnel and Veterans) Bill (OOB, the Bill) received royal assent and will shortly be adopted into United Kingdom (U.K.) law.  The Bill has been touted by the current Conservative government as being crucial in tackling “vexatious claims and [ending] the cycle of re-investigations against [the U.K.’s] Armed Forces.”  Nevertheless, the OOB is highly controversial as it may modify the application of international law in the context of British overseas military operations.  Although the House of Lords has recently made important amendments, this post will examine some of the remaining concerning aspects of the OOB in light of the U.K.’s international human rights obligations.  

Background 

The OOB’s was drafted in response to the thousands of “spurious legal claims” against soldiers and the Ministry of Defence (MoD) after the U.K.’s missions in Iraq and Afghanistan in the early 2000s.  Many of these cases were “lodged using legal aid with the Iraq Historic Allegations Team (IHAT), which was set up to examine serious accusations” arising from the Iraq missions.  While some had merit, the vast majority of these cases were unfounded, frivolous and/or vexatious, and their investigations resulted in a significant drain of the British judiciary and military’s resources. 

Although the OOB seeks to limit such claims from arising in the future, the Bill has a number of contentious provisions.  The OOB contains a “presumption against prosecution” if litigation is commenced five years after the date on which the criminal conduct is alleged to have occurred.  After five years, U.K. prosecutors will only permit criminal proceedings in “exceptional” circumstances.  In fact, prosecutions will only be allowed if the applicant receives the Attorney General’s express consent.  Furthermore, British prosecutors will have to give special consideration to a number of mitigating circumstances, such as the mental stress endured by service personnel in the context of military duties. 

The OOB also amends the Human Rights Act 1998 that allows the U.K. Secretary of State to derogate from the European Convention on Human Rights (ECHR) whenever the U.K. engages in future “significant overseas operations.” 

Recent Amendments by the House of Lords

Originally, the OOB applied to nearly all types of claims arising in overseas operations, with the exception of crimes against humanity of a sexual nature, as contemplated under Article 7(1)(g) of the Rome Statute of the International Criminal Court (ICC Statute).  This meant that all other violations of international criminal law or war crimes would be subject to the presumption against prosecution after the passage of five years - contrary to the U.K. 's obligations to investigate grave offences under the ICC Statute, the Convention Against Torture, and customary international humanitarian law.  The House of Lords recently amended this provision and made torture, war crimes, and other non-sexual crimes against humanity exempt from the application of the OOB making the Bill more inline with the afore mentioned sources of international law. 

Remaining Concerns of the Proposed Legislation 

While the House of Lords’ amendments were a step in the right direction, the OOB still has a number of concerning aspects in terms of U.K. 's human rights obligations.  As a party to the ECHR, the U.K. is bound by rulings of the European Court of Human Rights (ECtHR), which has held that in certain circumstances, the ECHR may apply extraterritorially to overseas military operations.  Where the ECHR applies, states parties are obliged to properly investigate human rights violations committed by soldiers stationed overseas and ensure that victims “have an effective remedy before a national authority.”  As the OOB currently stands, certain human rights violations and crimes not meeting the severity of those addressed by the House of Lords amendment will be subject to the presumption against prosecution.  These aspects of the OOB could incentivize the Ministry of Defence to conduct less stringent or flawed investigations and to even “leave investigations incomplete” in order to take advantage of the presumption against prosecution.

In fact, the drafters of the OOB have included the ability for the U.K. to derogate from the Convention entirely.  While Article 15 of the ECHR allows for derogation from its human rights provisions during times “of war or other public emergency threatening the life of the nation,” the OOB’s derogation provision would apply more broadly to any “significant overseas operations” including “peacekeeping […and] operations for dealing with terrorism, civil unrest or serious public disorder.”  Although state parties have evoked Article 15 in times of domestic disorder, terrorist threats, and emergencies, no such derogations to the ECHR have been made for modern instances of extraterritorial armed conflict or other kinds of military operations contemplated in the OOB.  The fact that the OOB could allow for derogation in nearly any event where U.K. soldiers are deployed overseas may go beyond the narrow derogation as contemplated in the ECHR. 

Conclusion 

The complex balance between international criminal law, humanitarian law, and human rights law is certainly blurred during times of extraterritorial military activity.  Yet, the OOB may have gone too far in favor of “lawfare” at the cost of the U.K.’s international obligations.  While the House of Lords has made significant amendments, when it comes into force, the OOB will limit the possibility of holding U.K. troops accountable for their wrongful conduct abroad.   As a result, avenues for redress for foreign victims will be greatly restricted. 

April 2021

Monthly News Updates: Human Rights Mechanisms - April 2021

By: Irene Aparicio García, Junior Research Associate, PILPG-NL

The following post summarizes and highlights some of the updates on the work of regional and international human rights mechanisms around the world in the month of April.

EUROPE

European Court of Human Rights | Protocol No. 15 to the European Convention on Human Rights will enter into force following Italy’s ratification

Protocol No. 15 to the European Convention on Human Rights will enter into force on August 1, 2021, following Italy’s ratification.  The Protocol includes amendments to the Convention, such as the reduction of the time period during which applicants may submit complaints to the Court, which will change from six months to four. [April 22, 2021]

European Court of Human Rights | The ECHR notifies Russia of Aleksey Navalnyy’s application regarding ill-treatment during his imprisonment

The ECHR has notified Russia of the submission of an application by Aleksey Navalny against the Russian state.  In January, Navalny, a well-known member of the Russian political opposition, complained that the ill-treatment he is suffering during his imprisonment threatens his right to life.  The notification includes several questions from the ECHR to Russia. [April 19, 2021]

European Court of Human Rights | Final judgment on the case of the unvaccinated children of the Czech Republic

The Court decided there was no violation of the right to respect for private life in a case concerning Czech children who were refused admission to nursery schools because they missed certain vaccinations.  The Court considered the request for medical reports proving that the applicants’ children were vaccinated as a valid measure aimed at protecting the health of the population.  The victims alleged that the Czech state violated their right to privacy after they were rejected from the schools. [April 8, 2021]

ASIA

ASEAN Intergovernmental Commission on Human Rights | AICHR suggests that ASEAN members take in refugees from Myanmar

The AICHR claimed that ASEAN members may take in refugees from Myanmar who are fleeing from the current political situation.  The representative of Malaysia to the AICHR first suggested this during a UN webinar on Myanmar’s crisis.  

The chief of the military junta, Min Aung Hlaing, attended the ASEAN Leaders Meeting on the crisis in Myanmar held in Jakarta on April 24.  Following the meeting, ASEAN has published a statement calling for the violence to stop and for a peaceful negotiation process. [April 24, 2021]

ASEAN Intergovernmental Commission on Human Rights | The AICHR discusses the situation in Myanmar and COVID-19 during its Annual Meeting  

The AICHR held its annual meeting between April 6 and 8.  The Representatives discussed the human rights situation in Myanmar and called on all parties to stop the violence.  The Representative of the Philippines called on Myanmar to respect the principles of the ASEAN Charter and the ASEAN Human Rights Declaration.  During the meeting, the Representatives also discussed the implementation of the ASEAN strategy to mitigate the consequences of the COVID-19 pandemic. [April 9, 2021]

AFRICA 

African Commission on Human and People’s Rights | Human Rights Watch urges the African Commission on Human and People’s Rights to protect human rights advocates in Chad 

Human Rights Watch calls on the African Union and on the African Commission on Human and People’s Rights to monitor the situation in Chad after the death of President Idriss Déby on April 20.  The death of the President followed the detention of protesters and members of the opposition before the April 19 national elections, allegedly won by Déby.  Human Rights Watch addressed the African Commission on Human and People’s Rights to prevent escalation of the situation. [April 20, 2021]

African Commission on Human and People’s Rights | Biannual meeting with the Inter-American Court of Human Rights held on April 14

The Registry Staff of the African Court on Human and Peoples’ Rights and the Inter-American Court for Human Rights held their biannual meeting on April 14.  Both parties discussed the progress and challenges in the compliance of their decisions given and the monitoring of their implementations. [April 14, 2021]

African Commission on Human and People’s Rights | Concern of the ACHPR over attacks by armed rebels in Mozambique

The ACHPR expressed concern over the violent attacks by armed rebels that took place in Palma, northern Mozambique, on March 24.  The ACHPR reminded Mozambique of its obligations under the African Charter on Human and Peoples' Rights and has urged the state to respect the rights of the victims. [March 30, 2021]

THE AMERICAS

 Inter-American Commission on Human Rights | The IACH welcomes the entry into force of the Escazú Agreement

The IACH welcomed the Escazú Agreement and its entry into force on April 22, the International Mother Earth Day.  The agreement, properly named the Regional Agreement on Access to Information, Public Participation and Justice in Environmental Matters in Latin America and the Caribbean, aims at protecting the human rights of environmentalist activists, including advocates of territory and land property rights. [April 21, 2021]

Inter-American Commission on Human Rights | The IACHR and the IACtHR publish their 2020 Annual Reports 

The IACHR has published its 2020 Annual Report.  The report includes the results and recommendations given throughout the past year and monitors the compliance with human rights and with the IACHR’s decisions in the Americas.  The report recognizes the challenge to the protection of human rights caused by the  COVID-19 pandemic, and also the progress made in prosecution processes.  Moreover, the IACtHR has also published its 2020 Annual Report, which includes a summary of the sessions held in 2021 and monitors compliance with its judgments. [April 16, 2021]

Inter-American Commission on Human Rights | IACHR issues a resolution on COVID-19 vaccines 

The IACHR has published a resolution calling for the fair distribution of COVID-19 vaccines in the Americas.  The resolution includes recommendations and calls for respecting human rights in the distribution and administration of the vaccine. [April 7, 2021]

UN MECHANISM

Human Rights Council (Special Rapporteur on the human rights of internally displaced persons) | UN experts welcomes the Iraqi’s Law on Yazidi [Female] Survivors

The Special Rapporteur on the human rights of internally displaced persons has welcomed the adoption of Iraq’s Law on Yazidi Female Survivors.  The law recognizes ISIS crimes against several minorities in Iraq, including Yazidis and Christians, as genocide and crimes against humanity.  Nevertheless, the Special Rapporteur also expressed concern over the children of Yazidi women who were conceived from rape by ISIS members.  As such, the women are frequently forced to abandon them and the law continues to not encompass this. [April 21, 2021]

UN High Commissioner for Human Rights | Statement on the conviction of Derek Chauvin in George Floyd’s case 

The UN High Commissioner for Human Rights issued a statement on the conviction of Derek Chauvin for the murder of George Floyd.  The High Commissioner stressed the significance of the verdict and also highlighted the long journey ahead in ending impunity for racial crimes.  She also called for continuing efforts to mitigate structural discrimination and encouraging equality even after the media coverage of this case fades. [April 21, 2021]

Human Rights Committee | Publication of the findings on Finland and Kenya

The UN Human Rights Committee has published its findings on Kenya and Finland regarding their compliance with the International Covenant on Civil and Political Rights.  The Committee recalled Finland of women’s inequality following the COVID-19 pandemic, while Kenya was reminded to address the electoral violence in the state. [April 14, 2021]

UN High Commissioner for Human Rights | Continued violence in Myanmar risks to amount to a humanitarian disaster similar to that of Syria in 2011

The UN High Commissioner for Human Rights urges all states to take effective measures against the human rights violations committed by Myanmar’s military, following yet another violent week.  The Commissioner has compared the Myanmar situation to that of Syria and has alerted the international community of the increasing possibility that the conflict may turn into a civil war.  As such, the Commissioner recalled the international community of their responsibility to not repeat the mistakes they made in Syria. [April 13, 2021]

Committee on the Elimination of Discrimination against Women | Decision against Libya regarding the detention of a women’s rights activist 

The Committee on the Elimination of Discrimination against Women published its decision on an individual complaint against Lybia.  The case concerns the illegal detention and torture of a woman that advocated for women’s rights in Lybia.  The woman was detained by members of a militia, and the Lybian state failed to investigate and punish the crime.  This is the first time that the CEDAW issues a decision on an individual complaint against a North African state. [April 7, 2021]

Human Rights Council (UN experts from Working Groups and Special Rapporteurs) | Concern over police abuses against protesters and journalists in Belarus

Following detentions during the protests surrounding Freedom Day in Belarus, several UN experts expressed their concern over arbitrary detentions and excessive force used by the police.   The experts call for an end to the abuses towards protesters and journalists. [April 1, 2021]

April 2021

Monthly News Updates: Domestic Prosecution of International Crimes - April 2021

By: Alexandrah Bakker, Research Associate, PILPG-NL 

The following post highlights developments from around the world in the domestic prosecution of international crimes.  This month saw developments at all stages of criminal proceedings, including the filing of criminal complaints, arrests of high-profile suspects, and long-awaited convictions.

EUROPE

Serbia | Trial opens in the case of former Kosovo Liberation Army member accused of war crimes

Proceedings began at the Belgrade Higher Court in the case against Nezir Mehmetaj, a former Kosovo Liberation Army fighter.  Prosecutors accuse Mehmetaj of participating in war crimes against civilians in June and July 1999.  Prosecutors allege that Mehmetaj killed seven people and participated in the looting and burning of houses. [April 22, 2021] 

The Netherlands | District Court of The Hague convicts Syrian man of war crimes

The District Court of The Hague sentenced a Syrian asylum-seeker to six years’ imprisonment following his conviction of membership of the terrorist organization Ahrar al-Sham and of the war crime of outrage upon personal dignity.  The war crime charge relates to a video the defendant filmed of himself and others spitting on and kicking enemy bodies. [April 21, 2021] 

Germany | Düsseldorf State Court convicts German woman of war crimes and crimes against humanity 

The Düsseldorf State Court convicted a German woman of participating in a foreign terrorist organization, neglecting her duties of care toward a minor, war crimes, weapons offenses, and being an accessory to a crime against humanity.  The woman traveled to Syria in 2015 to join the Islamic State, lived in apartments seized by the Islamic State, and used an enslaved Yazidi woman to clean her home and take care of her daughter. [April 21, 2021] 

Sweden | NGOs file a criminal complaint against members of the Syrian government over chemical weapons attacks

Four NGOs filed a criminal complaint with Swedish police against Syrian President Bashar al-Assad and other members of the Syrian government.  The complaint alleges that the individuals committed attacks using chemical weapons in 2013 and 2017, resulting in the deaths of hundreds of civilians. [April 19, 2021] 

Germany | NGOs file a criminal complaint against Chechen officials for crimes against humanity against the LGBTQ population

The European Center for Constitutional and Human Rights and the Russian LGBT Network filed a criminal complaint in Germany against five Chechen officials.  The complaint accuses the officials of persecution, unlawful arrests, torture, incitement to murder, and sexual violence, against members of Chechnya’s LGBTQ population. [April 18, 2021]

France | French authorities arrest Rwandan priest over the role in 1994 genocide

French authorities arrested Marcel Hitayezu, a Rwandan priest, over his alleged role in the 1994 Rwandan genocide.  Prosecutors charged Hitayezu with genocide and complicity in crimes against humanity for providing food to members of the Interahamwe, a paramilitary organization that played a large role in the genocide. [April 16, 2021]

AFRICA

Senegal | Senegalese court refuses Hissène Habré’s request for temporary leave from prison

The Dakar High Court refused Hissène Habré’s request for a 6-month leave from prison.  Habré, the former president of Chad, is serving a life sentence in Senegal following his conviction for crimes against humanity by the Extraordinary African Chambers in 2016.  Habré had requested temporary leave due to the Covid-19 pandemic. [April 19, 2021]

Rwanda | Rwanda Bureau of Investigation arrests woman deported from the United States over the role in 1994 genocide

The Rwanda Bureau of Investigation arrested Beatrice Munyenyezi, who had just arrived in Rwanda following her deportation from the United States for lying on her naturalization application.  Munyenyezi faces charges of murder and complicity in rape as a result of her position in charge of a roadblock during the genocide. [April 17, 2021]