1.1 INTRODUCTION
This study answers the question (How effective is the protection of human rights defenders in Cameroon?) and attains the objective (To examine the effectiveness in the protection of human rights defenders in Cameroon).
The chapter is also anchored around the social justice theory.Social justice is the ability people have to realize their potential in the society where they live. Also, social justice is defined as justice that conforms to a moral principle, such as that all people are equal. It is a theory which advocates for egalitarianism in the way persons are treated. This theory is important to this work in that it is going to stand as a base under which recommendations on how to effectively protect defenders can be done.
1.2 THE PROTECTION OF HUMAN RIGHTS DEFENDERS AS WHOLLY SUCCESSFUL
1.2.1 The existence of the framework for human rights defenders as evidence of success
In order to prevent and counteract the violence to which HRDs are regularly exposed while performing their activities, the United Nations and the former Organization of African Unity (OAU) have adopted several instruments and mechanisms intended to guarantee the protection HRDs.
In fact, the Universal Declaration of Human Rights (1948) and the International Covenant on Civil and Political Rights (1966) generally enshrine freedom of opinion, freedom of expression, freedom of assembly, and peaceful association. But in 1998, the United Nations adopted an instrument specifically dedicated to HRDs. This is the United Nations Declaration on HRD[1].
This reference instrument promotes the activities of HRDs and lays down the procedures for guaranteeing their rights. It codifies international standards for protecting the activities of HRDs around the world; recognizes the legitimacy of the activity of defending human rights and the need to protect this activity as well as those who defend it; sets out the duties of states and the responsibilities of each in terms of defending the rights of HRDs.[2]
This dynamic for the protection of HRDs has also been boosted to the African level by the OAU at the regional level. Thus, the Grande Baie Declaration and Plan of Action were adopted on April 16, 1999, by the first OAU Ministerial Conference meeting in Grande Baie, Mauritius, from April 12 to 16, 1999. These two instruments are the very first on the African continent to mention the specific protection of HRDs. They invite OAU Member states to take appropriate measures to implement the United Nations Declaration on HRDs[3]. This regional system is supplemented by the Kigali Declaration adopted on May 8, 2003, which emphasizes the role of HRDs and the need to protect them, like Article 28[4].
These various instruments developed at the above universal and African levels are reinforced by the existence of international and regional mechanisms for the protection of HRDs. This is the case with the United Nations Human Rights Committee, which examines, among other things, the reports presented by the states parties as well as communications from individuals on the human rights situation, etc.
The same is true of theAfrican Commission on Human and People’s Rights. There are also, alongside these mechanisms, rapporteurs specially appointed for HRDs.This is the case of the United Nations Special Rapporteur on the situation of defenders and the Special Rapporteur of the African Commission on the situation of HRD in Africa in the person of the President of the Commission on Human and People’’ Rights.
This international and regional framework demonstrates the centrality of taking into account the crucial issue of the protection of HRDs. In Cameroon, HRDs remain constrained by the absence of a real specific instrument to guarantee HRDs.
1.3 FAILURES AND CHALLENGES IN THE PROTECTION OF HUMAN RIGHTS DEFENDERS IN CAMEROON
Several challenges are encountrered in the protection of Human rights defenders such as, the absence of a national legal framework for the protection of hrds.They would be examined in the paragraphs that follow.
1.3.1 The Absence of a National Legal Framework for the Protection of HRDs
Although it is a global concern, the protection of HRDs in Cameroon is not yet subject to a specific legal framework. Admittedly, laws adopted following the liberalization of political and civic space in 1990 allow HRDs to enjoy certain freedoms. These are specifically Laws No. 90/43 relating to the conditions of entry, stay, and exit of the Cameroonian territory; Law No. 90/052 on freedom of social communication; No. 90/053 relating to the freedom of association and Law No. 90/055 fixing the regime of gatherings and public demonstrations. These laws thus constitute the legal basis on which HRDs in Cameroon rely to carry out their activities (travels, gatherings, associations, and communication).
However, the absence of a specific text on the protection of HRDs remains a genuine handicap. In 2021, Senator Pierre Flambeau Ngayap submitted to the office of the Cameroonian Senate a bill on the promotion and protection of HRD in Cameroon (REDHAC 2022: 34). This proposal currently represents the only hope of obtaining a legislative instrument specifically dedicated to HRDs.
For the time being, the emptiness of a specific legal framework for the protection of HRDs is the main cause for the persistence of violations against them. For example, HRDs are generally victims of “criminalization” by extension or by rebound, a strategy that consists of “taking advantage of the criminal law and other legal provisions to attack [them], with the aim of curbing their work of defense and promote fundamental freedoms”[5].
According to Front Line Defender (2017:9), the criminalization of HRDs is more pronounced when it comes to the area of national security. For example, the 2014 law on terrorism has been used by Cameroonian authorities to target HRDs. For illustration, the correspondent of Radio France International in the Hausa language, Ahmed Abba, had been sentenced to 10 years in prison and a fine of €84,000 by the Yaoundé military court for “non-denunciation of terrorism” and “money laundering” revenue related to terrorist acts”.[6]
Similarly, in 2017, two civil society leaders, namely lawyer Nkongho Felix Agbor-Balla and Dr. Fontem Aforteka’a Neba, representatives of the English-speaking movement, were arrested by the Cameroonian government because they were demanding the release of students and teachers imprisoned between the end of 2016 and the beginning of 2017.
1.3.2 Restrictions on freedom of expression and association
The authorities have often been intolerant of criticism of the government and/or its policies human rights defenders. HRDs investigating or advocating against forms of abuse of office have been arrested and detained by members of the security forces, charged and/or imprisoned for defamation. Some of them have also been subjected to beatings and other forms of ill-treatment by members of the security forces.
Contra Nocendi notes in this regard that in Cameroon’s 5th Periodic Report, it stated human rights defenders, including “Journalists and political opponents are not subject to intimidation, threats or legal harassment by public authorities. The State guarantees the exercise of their activities as long as they do not violate criminal law.”[7]
Based on information received from HRDs on the ground as well as relevant partner organisations, Contra Nocendi has found several acts of violations of HRDs rights which are of grave concern.
For instance, Mr. Bikoko, executive president of the Central Trade Union of the Public Sector and focal point for Dynamique Citoyenne, a network of Cameroonian civil society organisations, had been arrested in together with his colleagues at a workshop organized to mark the International Day of Democracy in September 2015 by security forces in Yaoundé. The police had ordered the suspension of an event they organized, alleging that it could not be held because it had not been authorized by the divisional office, even though the law only required such prior notices for demonstrations.
Also, In January 2016, the Court of First Instance of Mundemba sentenced Mr Besingi to either pay a fine or serve one year imprisonment, on charges of conducting unlawful assemblies, and organising and inciting protests. Mr Besingi is an environmental rights defender and the director of Struggle to Economize the Future Environment, an NGO which has asserted the land rights of local communities in the context of the development of palm oil plantations by the American agribusiness company. He has also previously been subjected to acts of intimidation, threats, arrests, beatings and judicial harassment in relation to his work. On 25 September 2017, Nasako Besingi was arbitrarily arrested by local police officers, gendarmes and army officers in his office in Mundemba, Ndian Division. On 28 September 2017, he was brought before the Buea Military Tribunal where he was questioned by the investigating judge, following which he was taken back to Buea prison. While the investigation is still ongoing, the initial charges against him include allegations of insurrection, threats, hostility and promoting false information. This is not the first time Mr. Besingi is being targeted for his work in promoting and defending human rights. Previously in January 2016, the Court of First Instance of Mundemba sentenced Mr Besingi to either pay a fine or serve one year imprisonment, on charges of conducting unlawful assemblies, and organising and inciting protests. Mr Besingi is an environmental rights defender and the director of Struggle to Economize the Future Environment, an NGO which has asserted the land rights of local communities in the context of the development of palm oil plantations by the American agribusiness company. He has also previously been subjected to acts of intimidation, threats, arrests, beatings and judicial harassment in relation to his work.
Again in the case of members of Esu Youth Development Association, although five of the members that were detained since May 2016 were released in May 2017, they, and others were arrested in relation to their opposition to landgrabbing in the Esu community. The Bamenda Appeal Court granted bail to the youth leaders following several adjournments, however, it did not set a date for their appeal hearing regarding the lack of jurisdiction.
The above cases are of particular concern, given that these rights violations were clearly related to their work in the defence and promotion of human rights. Furthermore, it is noted that besides actual violations that occur towards HRDs in violation of their civil and political rights, other HRDs in Cameroon have faced acts of threats[8] and intimidation, as well as other acts of judicial harassment.[9]
1.3.3 Security concerns and human rights obligations
In early 2015, President Paul Biya ratified an anti-terrorism legislation[10] that allowed for Cameroonian citizens to be charged in military courts and to face the death penalty if they, either as individuals or in a group, carried out, abetted, or sponsored terrorism. The designation of military tribunals to try civilians contravenes the non-derogable right to fair trial under the International Covenant on Civil and Political Rights. Military tribunals do not qualify as independent and impartial courts, as being part of the armed forces, they fall under the executive branch of the government. This said law contains vague definitions of “terrorism” including disturbing the normal functioning of the public services, or the provision of essential services to the population, or creating a situation of crisis within the population, and has been criticized as being capable of being used as a means to criminalize opponents of the government. Starting from October 2016, lawyers, teachers and other HRDs initiated a series of protests against discrimination in the Anglophone regions of Cameroon. In response to the protests, the internet was shut off in Anglophone parts of the country for a number of months. HRDs leading the call to respect the human rights of citizens in these regions were the first to be targeted and charged by the authorities under the 2014 anti-terrorism law.
Several of these HRDs, including Nkongho Felix Agbor-Balla, were recently released and had the charges against them dropped. Many of them, including human rights lawyer and President of the now-banned Cameroon Anglophone Civil Society Consortium (CACSC), Nkongho Felix Agbor-Balla had been in detention since January 2017 for their involvement in organising non-violent civil disobedience to protest conditions in schools and to demand the release of imprisoned students and teachers in late 2016 and early 2017. In line with the anti-terrorism law, Nkongho Felix Agbor-Balla and other human rights defenders were charged in a military court with offences including hostility against the government and secession.
While the researcher recognises State security and stability to be very important factors shaping a country’s policy and governance structure, it is nevertheless weary of the infringement the anti-terrorism law has on human rights and freedoms protected under international human rights law, as has been seen in the case of Nkongho Felix Agbor-Balla and other HRDs where there is a pressing need for distinguishing between persons whose actions or declarations are directly intended to terrorise the public or create widespread insurrections, and persons who advocate for the exercise their rights and freedoms in a peaceful and lawful manner. Furthermore, the competence given solely to military tribunals under this law is problematic under international human rights law, given that being part of the armed forces, they neither qualify as independent or impartial courts.
1.3.4 Governmental Posture towards International and Nongovernmental Investigation of Alleged Abuses of Human Rights
A number of domestic and international human rights groups investigated and published findings on human rights cases. Government officials rarely were cooperative and responsive to their views. Government officials impeded many local human rights NGOs by harassing their members, limiting access to prisoners, refusing to share information, and threatening violence against NGO personnel. The government took no action to investigate or prevent such occurrences. The government criticized reports from international human rights organizations by accusing them of publishing baseless accusations.[11]
On August 2, Human Rights Watch (HRW) released a report entitled Cameroon: New Abuses by Both Sides, which accused government forces of destruction of property, rape, killings, execution of civilians, and looting in the Northwest and Southwest Regions. In response military spokesman Cyrille Atonfack Guemo firmly rejected what he referred to as an “outrageous and provocative” report. In an August 5 statement, he declared, “Everything appeared to clearly indicate that the multiple positions taken by HRW are intended only to discredit the defense and security forces.”
In an August 26 press release, Minister of Territorial Administration Paul Atanga Nji announced an inquiry into the registration of all foreign NGOs operating in Cameroon. In the release Atanga Nji ordered them to deposit all required original documentation at his ministry by the end of September.[12]
The order specifically asked for a dossier comprising an original copy of the document authorizing the organization in Cameron; two copies of the organization’s constitution; the instrument appointing the organization’s representative; a legalized photocopy of the national identity card or the representative’s passport that is less than three months old; a map indicating the location of the organization’s headquarters, or of its legal representative’s office and permanent telephone address; a complete list of non-national staff working for the organization; their curricula vitae and certified copies of their passports; a complete list of local personnel including their work contracts; and the organization’s annual activity program. Minister Atanga Nji added that foreign organizations that did not submit the documents prior to the required deadline would be suspended[13]. As of October the Ministry of Territorial Administration had relaxed some of the requirements after strong pushback from civil society organizations and international NGOs.[14]
Observers saw the minister’s decision as a strategy to intimidate human rights organizations and possibly ban those that highlighted government abuses. As in the previous year, human rights defenders and activists received anonymous threats from persons suspected to be affiliated with the government by telephone, text message, and email. In particular this was the case for the Central Africa Human Rights Defenders Network was a consistent target of the government.
On July 21, Chief Warrant Officer Bako Jean Oscar, commander of research Brigade I in Bonanjo, Douala, summoned Maximilienne Chantal Ngo Mbe, executive director of Network for Human Rights Defenders in Central Africa, to appear before him on August 9. The summons did not contain further information on the case in question, and authorities refused to specify what charges, if any, they were investigating. Ngo Mbe received an additional summons on August 13 from the Legion Gendarmerie to appear on August 16 again without any specified reason; however, the date in question fell on a holiday so she was not required to appear. Ngo Mbe received a subsequent summons to appear before the Yaounde Scientific and Judicial police in November, ordering her to appear on December 28; however, her lawyers petitioned to have the date postponed until February 2022.[15]
1.3.5 Ignorance as a Cause of the Plight of HRDS
Ignorance takes a diverse dimension. It may involve (and in most cases it does) ignorance on the part of the perpetrator with regards to the role of HRDS in the promotion and protection of Human Rights .Ignorance may also be on the part of the victim defender with regard s to the rights available to them or safeguards against their violation out of ignorance, many human rights defenders are victimized.
There is a great need for education and sensitization even to human rights defenders in order to raise awareness and consciousness in them on the risks and challenges involved in promoting and protecting Human Rights and Freedoms Progressive teaching and education on the plight of human rights defenders will greatly reduce the prevalence of violations that target them.
1.3.6 Perception of Human Rights Defenders and Human Rights activity
Many still have a negative perception of human rights activism. .In most communities, human rights defenders are perceived and treated as though they were ‘opponents of the state’ and their activities are often seen as those activities requiring repression or punitive measures. The cynicism with which human rights activity is often perceived is largely due to the problem of ignorance .State authorities and governments must thus be made to see human rights defenders as collaborators and not as opponents.
An illustrative case is that of Mr Sylvester Toh. On his National Identity card, there is an indication that he is a Human Rights Defender by Profession. According to Mr. Toh most or the violation or harassments he experiences results from the simple fact of his being a human rights defender and nothing else. The presentation of his identity card to any law officers often results either in suspicion of his movements, or in confrontation with the forces of law and order.
4.3.7 The Sensitive Nature of the Tasks of Human Rights Defenders
The task of protecting human rights requires the intervention of defenders into some issues including those that can threaten national unity and peace and those issues with a very sensitive character. In such a situation human rights defenders must be aware that the e objective of human rights work is to protect and ensure respect for human rights .An example of a sensitive issue in the North West Region is the issue of the Southern Cameroon’s National Council (SCNC)[16]. As a human rights defender, I am not interested in the debate as to whether or not the arguments of the SCNC activists are legitimate.[17] It is never the less a reality that the SCNC activists are defending the right to ‘self determination’ which has been recognized in other prominent human rights instruments.
Human rights defenders simply by reason of the fact that they handle sensitive issues are sometimes victims of different forms of harassment and intimidation. The case of Gorji Dinka v. Cameroon (2005)[18] is instructive given that the complainant was persecuted because he criticized “… the ‘subjugation’ of Ambazonians, whose human rights were allegedly severely violated by members of the Franco-Cameroonian armed forces as well as militia groups, riots broke out in 1983, prompting Parliament to enact Restoration Law 84/01, which dissolved the union of the two countries”[19]. The author then became head of the ‘Ambazonian Restoration Council’ and published several articles, which called on President Paul Biya of the Republic of Cameroon to comply with the Restoration Law and to withdraw from Ambazonia. The first reaction of perpetrators could be to sweepingly link the defender to the course pursued by the persons being defended. Some human rights activities could easily be linked up with terrorism and all persons defending those involved in the activity as ‘terrorists’.
In a more recent case involving Alvine Nkomthe state of Cameroon expressed dissatisfaction with a grant she had won to promote the rights of sexual minorities[20].
1.3.8 State Authorities as Perpetrators
When state authorities to whom HRDs can run for rescue in times of violations are also perpetrators of violations, the situation of the defender as well as the victim is made worst. Usually, where a state authority is a perpetrator, then other state authorities may be complicit by way of ‘inaction’ to a complaint by a HRD or by their failure to take an appropriate measure of redress or remedy for the situation. It has been suggested[21] that where a state authority is an offender, then the state should be held vicariously liable. This could be true yet it is the humble submission of this student, that since criminal responsibility is personal, the state can only be held responsible in respect of civil actions or, in the case where a criminal offense gives rise to the civil claim.
State authorities include a vast class as well. It may be judges in the court rooms and other members of the judiciary. It may be administrative personnel as well as legislators by way of the enactment of restrictive laws. Usually however the most common state authorities are forces of law and order, police officers prison staff, they most often are those at the local levels, even though state authorities at the national locals can also be perpetrators of violations.
From previous reports (2005-2009) of the ministry of justice on the state of Human Rights in Cameroon the police and other security forces are the most visible perpetrators of violations against Human Right Defenders. This is visible through the conduct of illegal searches of Human Rights offices, and illegal arrests of defenders. Members of the judiciary such as state counsels (in Cameroon) are often perpetrators by way of the use of judiciary powers. In the case of The People v. Kpunsa Moses Komban & 4 Ors[22], the State Counsel had ordered the detention of accused and during a hearing to determine an application for the release of the accused persons the learned State Counsel, like Pontius Pilate washed his hands of the detention of the accused persons by submitting that;
“The applicants are not being illegally kept. We would have gone ahead to prefer charges and have them prosecuted in this court, but realizing that we lack the jurisdiction to do so, they are being kept by the Min[23]ister of Justice and keeper of the seals on behalf of the government of Cameroon”.
Some states authorities may by way of restrictive regulations push HRDs into administrative illegality and use such illegality as a pretext for their arrests and detention.
State authorities may fail to investigate complaints lodged by Human Rights Defenders[24] and by failing to investigate or take temporary protective measures where needed. In such a case by such failure, they breach the fundamental obligations owed to the society. In some cases, police refuse to register or even to act on complaints raised by HRDs. If the case goes to court the courts may be reluctant to put the perpetrators to trial. Inaction in the case of threats usually leads to the actual occurrence of the act of threat. This was the case with SITARA ACHAKZAI[25] (April 2010) of Afghanistan who had complained to government authorities about threats that she had been receiving, but the authorities had done nothing to protect her.
1.3.8 Human Rights Defenders Are Sometimes the Cause of Their Plight
The job of a Human Rights Defender being a risk taking job also requires much skill, tact and professionalism as well as sensitization on the part of Human Right Defenders. With out these qualities human rights defenders will continually be victimized. The case of Magdalene AFITE is illustrative. Magdalene AFITE was facing threats for her determination to denounce the exaction and abuses related to the management of the social unrest in February 2008. The Special Rapporteur of the African Commission on Human and People Rights, expressed concern for the case of Afite.
Government opened inquiry to determine the alleged facts and when Magdalene was asked to provide useful and helpful information for the inquiry she said that she would not submit a petition nor make any declaration because the ensuing inquiry would be inefficient.
It is humbly submitted, that it is unprofessional for a victim defender to refuse giving information which will be helpful in determining their complaints, simply on the basis that the complaints would not help in resolving the situation.
1.3.9 Criminalization of Land Defenders by Palm Oil Plantations
In 2009 the Cameroonian government granted American company Herakles Farms company over 73,000 hectares of land, despite the fact that any amount of land in excess of 50 hectares can only be granted by presidential decree[26] without the Free, Prior, Informed Consent of the communities whose livelihoods depend on the forests that occupied that land. The dispossession of traditional lands used for foraging, subsistence farming, and inheritance directly affects the livelihoods of communities and their food sovereignty. Despite these human rights and environmental concerns, the Government of Cameroon recently renewed the land lease to a now independent subsidiary SG Sustainable Oils for another 3 years without proper consultation of affected communities[27].
Meanwhile, environmentalists who are organizing against the palm oil plantations have been targeted and criminalized. Nasako Besingi, Executive Director of Struggle to Economize Future Environment (SEFE), is an internationally renowned human rights defender and an environmental activist in Cameroon. In recent years, he has been arrested, assaulted, and sued in court for helping communities from the southwest region challenge Herakles Farms. In January 2016, he was sentenced by a local court to either pay a fine of 344,400 CFA Francs or serve one year’s imprisonment, on charges of “participating in the organization and holding of an undeclared public meeting.” The charges were based on allegations made against him by Herakles Farms, following a demonstration, in which Nasako Besingi distributed t-shirts displaying the quote “No plantation on our land. Herakles farms out!” On September 25, 2017, he was arrested in Mundemba, Ndian Division and taken to an unknown location. No information was given to his family and lawyer about the charges against him until days later. After being denied bail and spending 2 months in prison, he was released on November 27 and all charges dropped.
1.4 CONCLUSION
It may be concluded that even though state authorities perpetrate violations against human rights defenders, there are individuals still within the ranks of state authorities who are committed to denouncing human rights abuses in all their forms especially when they are directed against human rights Defenders. In the case of The People v. Nyah Henry & ors decided by the Bamenda Court of First Instance in 2001 Justice Bea Abednego Kalla took a stance to uphold the presumption of innocence, which is a cardinal principle of human rights. In the words of the learned Judge;
“Everyone charged with a penal offence has the right to be presumed innocent until proven guilty according to the law in a public trial at which he has had all the guarantees necessary for his defense. So therefore I will be doing no justice in this matter to call upon these people to take plea before me with the gross violation of their constitutional and human right before my very nose. A corollary of that reasoning is that the defendants are presumed to have lost their status of innocent citizens who are thus pursued by persecutors and not prosecutors”.
This explains the positive role that state authorities can play in protecting human rights defenders from violations that target them as a result of their human rights work. It is worth noting that the fact that a person is a human rights defender does not deny that person of the right to be presumed innocent until proved guilty.
[1] Fédération Internationale Pour Les Droits Humains,”Mecanismes De Protection Des Defenseurs Des Droits De L’homme” 2010.
[2] The Declaration on Human Rights Defenders. General Assembly Resolution A/RES/53/144 adopting the Declaration on Human Rights Defenders.
[3] La première Conférence ministérielle de l’OUA sur les droits de l’homme en Afrique réunie à Grand Baie (Maurice) du 12 au 16 avril 1999
[4] La première Conférence ministérielle de l’Union Africaine sur les Droits de l’Homme en Afrique réunie le 8 mai 2003 à Kigali (Rwanda).
[5] Steve Tametong, Ph.D. and Vanessa Aboudi. ‘’The Protection of Human Rights Defenders in Cameroon”The Nkafu Policy Institute.2023.
[6] (Front Line Defender 2017: 9).
[7] See for example, Cameroon’s 5th Periodic Report, CCPR/C/CMR/5, at 2.4, page 28.
[8] Executive Director of REDHAC, Maximilienne Ngo Mbe, a coalition of human rights defenders active in eight countries in central Africa, based in Douala, for example, recently received death threats in relation to her human rights work, and more particularly for speaking out on the repression of a social protest movement under way in English-speaking Cameroon since November 2016.
[9] Contra Nocendi notes here for example the reports received regarding the ongoing judicial harassment targeting members of the Organic Farming for Gorillas (OFFGO), a group of farmers promoting organic farming, environmental protection, opposing land grabbing in the North-West Region of Cameroon.
[10] Law No. 2014/028 of 23rd December 2014 on the suppression of acts of terrorism in Cameroon
[11] Cameroon Human Rights Report 2021.
[12] Cameroon Human Rights Report 2021.
[13] see also section 2.b, Freedom of association
[14] Cameroon Human Rights Report 2021.
[15] Cameroon Human Rights Report 2021.
[16] This issue is being addressed in this study because it is one of the issues that were confronted in the field and there is need to contextualize the issue in the study.
[17] To qualify as a human rights defender one must not concern himself with the legality of the arguments being raised but with the protection of human rights and freedoms.
[18] AHRLR 18 (HRC 2005)
[19] See paragraph 2.5 of AHRLR 18 (HRC 2005)
[20] The rights of sexual minorities is not globally accepted in many African states given that some practices such as homosexuality run contrary to generally accepted ethically standards and values and even the law in the country.
[21] By Mr Ndi Nelson in an interview granted this student on December 17 2010
[22] Suit No HCK/02m/01-02
[23] See Ruling of the High Court Kumbo in Suit No HCK/02m/01-02
[24] An example is where a particular human rights defender lodges a complaint about threats to his or her security and state authorities fail to investigate into the allegations of threat. Sometimes the threats are followed by the actual occurrence of the subject of threat.
[25] See World Report (2010), Human Rights watch, p.5
[26] Gaworecki, Mike. “Cables Reveal US Gov’t Role in Herakles Farms Land Grab in Cameroon.” Conversation News. Mongabay, 30 Aug. 2016. Web. 08 Mar. 2017.
[27] “Take Action Cameroon: Palm Oil vs. People and the Planet.” Cultural Survival. Cultural Survival, 10 Oct. 2016. Web. 02 Mar. 2017.