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).

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