[1995] ACHPR 2

[1995] ACHPR 2

The Commission found that the applicant had not demonstrated exhaustion of local remedies in Tanzania or that such remedies were unavailable, ineffective, or unreasonably prolonged. The mere fact that the Tanzanian Film Company had no property in Zaire and that the embassy was immune from seizure did not suffice to...

Source-derived case information.

Citation
[1995] ACHPR 2
Parties
Applicant: Alberto T Capitao; Respondent: Tanzanian Film Company; Respondent: Embassy of Tanzania in Kinshasa
Court
African Commission on Human and Peoples Rights
Jurisdiction
Uganda
Case Number
Communication 53 of 1991
Procedural Posture
Communication / Decision on Admissibility
Outcome
inadmissible for lack of exhaustion of local remedies
Legal Topics
Diplomatic Immunity, Exhaustion of Local Remedies, Enforcement of Foreign Judgments
Source Language
en
Public International Law Diplomatic Immunity Exhaustion of Local Remedies Enforcement of Foreign Judgments

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Parties

Alberto T Capitao

Applicant

Tanzanian Film Company

Respondent

Embassy of Tanzania in Kinshasa

Respondent

Procedural Posture

Communication / Decision on Admissibility

  1. 1 Whether the complaint is admissible before the Commission given the alleged failure to exhaust local remedies.
  2. 2 Whether the complainant has any recourse against a foreign state that refuses to pay a judgment debt due to diplomatic immunity.

Ratio Decidendi

The Commission found that the applicant had not demonstrated exhaustion of local remedies in Tanzania or that such remedies were unavailable, ineffective, or unreasonably prolonged. The mere fact that the Tanzanian Film Company had no property in Zaire and that the embassy was immune from seizure did not suffice to establish that all local remedies had been exhausted or were unavailable. Therefore, the complaint was inadmissible at this stage, but could be resubmitted if the applicant later exhausted local remedies or proved their unavailability or ineffectiveness.

Court Disposition

inadmissible for lack of exhaustion of local remedies

Orders

  • The communication is declared inadmissible for failure to exhaust local remedies.
  • The complainant may resubmit the case if local remedies are exhausted or shown to be unavailable, ineffective, or unreasonably prolonged.