A state that has violated the rights enshrined in the African Charter is obliged to take
measures to ensure that the victims of human rights abuses are effectively compensated and
restituted (Reverend Christopher R. Mtikila v The United Republic of Tanzania, application
011/2011, ruling on reparations, 13 June 2014, para 125; Beneficiaries of late Norbert Zongo,
Abdoulaye Nikiema alias Ablasse, Ernest Zongo and Blaise Ilboudo and the Burkinabe Movement for
Human and Peoples’ Rights v Burkina Faso, Reparations, Application No 013/2011, 5 June 2015 paras
20 & 21). However, for reparations to accrue, there must be a causal link between the
internationally wrongful act and the alleged prejudice (Zongo, Reparations, para 21)
Both material and moral damages must be repaired and may be in the form of restitution,
compensation and satisfaction or a combination of these (Zongo, Reparations, paras 26 & 29).
The Court has in its case law noted that it can provide for some reparations in its judgment
(Wilfred Onyango Nganyi & 9 others v Tanzania v The United Republic of Tanzania,
application 006/2013, judgment, 18 March 2016 para 190) and can also decide in a further
judgment after submissions by the parties so far deferred the issue of determination of
reparations to be determined after the adoption of the merits judgment (Lohé Issa Konaté v
Burkina Faso, application 004/2013, judgment, 5 December 2014 para 174).