1 See generally: Sarkin, J.and Binchy, W., eds., Human Rights, the Citizen and the State. Dublin: Round Hall, Sweet and Maxwell, 2001.Google Scholar

2 See further: Sarkin, J. Van de Lanotte, J., and Haeck, Y., eds. Resolving the Tensions Between Crime and Human Rights: European and South African Perspectives. Antwerpen: Maklu, 2001.Google Scholar

3 The Protocol to the African Charter on Human and Peoples’ Rights Establishing an African Court on Human and Peoples’ Rights.Google Scholar

4 These countries are Algeria, Burkina Faso, Burundi, Gambia, Libya, Lesotho, Mali, Mauritania, Rwanda, South Africa, Senegal, Togo, Uganda, Ivory Coast, and the Comoros.Google Scholar

5 It was adopted by the Assembly of Heads of State and Government of the Organization of African Unity (OAU), at its 34th Ordinary Session, June 1998, in Ouagadougou, Burkina-Faso.Google Scholar

6 Article 34(3).Google Scholar

7 Most countries in Africa, for example, went through a colonial period under the domination of countries such as France, Germany, Great Britain, Italy, Belgium, and Portugal.Google Scholar

8 The term “genocide” only received formal and legal recognition at the Nuremberg trials, although the Charter of the Tribunal did not expressly use the term. The term was coined in the 1940s by Raphael Lempkin. The Genocide Convention was adopted by the UN General Assembly only in 1948.Google Scholar

9 For example, the legacy of the 1884-85 Berlin Conference, where the colonial powers of Europe met in Berlin to carve up Africa among themselves as colonies and dependencies, still has a major effect on the extent to which conflict racks the continent. See Sarkin, J. “Finding a solution for the problems created by the politics of identity in the Democratic Republic of Congo (DRC): Designing a consitutional framework for peaceful co-operation” in The Politics of Identity, Konrad Adenauer Foundation, ed., 2002. It is not surprising that, against the backdrop of these inexcusable and arbitrary colonial border placements and policies of rigid ethnic identity in a pervasive environment of underdevelopment, 20 of the 48 genocides and “politicides” that occurred worldwide between 1945 and 1995 took place in Africa. See Solomon, H., “Analysing conflicts” in Searching for Peace in Africa: An overview of Conflict Prevention and Management Activities, Amsterdam: The European Platform for Conflict Prevention and Transformation, 1999, 34. See further: Brogan, P., World Conflicts: Why and Where They are Happening, London: Bloomsburg Publishing Ltd., 1992.Google Scholar

10 The declaration of the World Conference against Racism held in 2001 recognized in article 158 “that these historical injustices have undeniably contributed to the poverty, underdevelopment, marginalization, social exclusion, economic disparities, instability and insecurity that affect many people in different parts of the world, in particular developing countries. The Conference recognizes the need to develop programs for the social and economic development of these societies and the Diaspora, within the framework of a new partnership based on the spirit of solidarity and mutual respect, in the following areas: …” United Nations A, General Assembly Distr., General, A/Conf. 189/ 24 September 2001, Original: English, World Conference Against Racism, Racial Discrimination, Xenophobia And Related Intolerance Durban, 31 August-8 September 2001. Adopted on September 8, 2001 in Durban, South Africa (Final Version released on December 31, 2001).Google Scholar

11 An example of this, which will be dealt with in much greater detail below, is the case of the genocide committed on the Hereros in Namibia at the beginning of the twentieth century. The argument made by President Roman Hertzog of the Federal Republic of Germany, when visiting Namibia in 1998, was that no crime had been committed as no law existed then which proscribed such conduct.Google Scholar

12 See Universal Declaration of Human Rights Article 8; International Covenant on Civil and Political Rights, Article 2(3) (a), and the Convention Against Torture and Other Cruel, Inhuman, or Degrading Treatment or Punishment, Article 14 (1).Google Scholar

13 See the Chozrow Factory case, Publications of the Permanent Court of International Justice, Collection of Judgments, Series A, No. 9, 21; Series A, No. 17, 29 (June 27, 1928). This case was cited with approval in the 14 February 2002 judgment, Democratic Republic of the Congo v. Belgium, in which the court held that “reparation must, as far as possible, wipe out all the consequences of the illegal act and re-establish the situation which would, in all probability, have existed if that act had not been committed.”Google Scholar

14 An example is the finding of the Inter-American Court of Human Rights decisions in the Velásquez Rodriguez case. See Inter-American Court of Human Rights, Velásquez Rodriguez v. Honduras, Serie C, nr. 7, Judgment of July 21, 1989 (Compensatory Damages), para. 71. See further Tomuschat, C. “Reparation for victims of grave human rights violations” in Tulane Journal of International and Comparative Law, 10 (Spring 2002): 157.Google Scholar

15 See Bazyler, M. J. “The Holocaust Restitution Movement in comparative perspective” in Berkeley Journal of International Law 20 (2002): 11.Google Scholar

16 Cases have also been filed in terms of the Torture Victims Protection Act of 1991. Act 12, 1992, P.L. 102-256, 106 Stat. 73. However, the court in Beanal v. Freeport-McMoran, Inc. held that, because the TVPA used the term “individual,” Congress did not intend to include corporations as defendants. 969 F. Supp. 362, 382, (E.D. La. 1997).Google Scholar

17 An example of the growth in the number and type of suits filed is one against Royal Dutch Petroleum Company and Shell Transport and Trading Company (Royal Dutch/Shell). In Wiwa v. Royal Dutch Petroleum, 96 Civ 8386 (S.D.N.Y., filed November 8, 1996) 226 F.3d 88 (2nd Cir. 2000), Shell was charged with complicity in the November 10, 1995 hanging of Ken Saro-Wiwa and John Kpuinen, two of nine leaders of the Movement for the Survival of the Ogoni People (MOSOP), in the torture and detention of Owens Wiwa, and in the wounding of a woman, peacefully protesting the bulldozing of her crops in preparation for a Shell pipeline, who was shot by Nigerian troops called in by Shell. The case was brought under the ATCA and the Racketeer Influenced and Corrupt Organisations Act. Another case was brought against President Robert Mugabe of Zimbabwe. This case was, however, objected to by the U.S. government, citing concerns that he might be entitled to diplomatic immunity. See “Zimbabwe president accused of orchestrating terror in United States suit.” CNN.com, September 10, 2000. See further: Kirgis, F.L. “Alien Tort Claims Act proceeding against Robert Mugabe” in American Society of International Law Insights, (September) 2000, 2.Google Scholar

18 Bossuyt, M.and Vandeginste, S., “The issue of reparation for slavery and colonialism and the Durban World Conference against Racism” in Human Rights Law Journal, 22 (2001): 25.Google Scholar

19 See Sebok, A.J. “Slavery, reparations, and potential legal liability: The hidden legal issue behind the U.N. racism conference” in http://writ.news.findlaw.com/sebok/20010910.html (last visited on May 23, 2002).Google Scholar

20 In the context of the Herero people of Nambia's claim, Harring claims that the “Herero are aware that reparations regimes operant in the world today are political and not legal. But, these political actions have a common history of being moved by extensive legal posturing, creating a powerful moral climate supporting reparations, and shaping public opinion.” Harring, S.L. “German reparations to the Herero nation: An assertion of Herero nationhood in the path of Namibian development?” in West Virginia Law Review 393 (Winter 2002): 410.Google Scholar

21 Zia-Zarifi, S. “Suing multinational corporations in the U.S. for violating international law” in UCLA Journal of International Law & Foreign Affairs, 4 (1999): 81, 85. See further: Frey, B., “The legal and ethical responsibilities of transnational corporations in the protection of human rights” in Minnesota Journal of Global Trade 6 (1997): 153.Google Scholar

22 See, for example, Fernandez, L. “Possibilities and limitations of reparations for the victims of human rights violations in South Africa” in Confronting past injustices: Approaches to amnesty, reparation and restitution in South Africa and Germany, Rwelamira, M. and Werle, G., eds., Durban, Community Law Centre; University of the Western Cape, 1996, 65-78.Google Scholar

23 There are obstacles that plaintiffs would have to surmount for a claim to succeed against a country. In the U.S., the Foreign Sovereign Immunities Act often operates to insulate state actors from liability. See further: Saunders, L. “Rich and rare are the gems they war?: Holding De Beers accountable for trading conflict diamonds” in Fordham International Law Journal, 2001, 1402. The Supreme Court in Argentine Republic v. Almerada Hess Shipping Corporation held that the Act of 1976 established a general immunity of foreign states from suits before American courts. See Argentine Republic v. AlmeradaHess Shipping Corp., 488 U.S. 428 (1989).Google Scholar

24 See Penrose, M. “It's good to be the king!: Prosecuting heads of state and former heads of state under international law” in Columbia Journal of Transnational Law 39 (2000): 193; Perez, A., “The perils of Pinochet: Problems for transitional justice and a supranational governance solution” in Denver Journal of International Law and Policy 28 (Spring 2000): 175; Pierson, C., “Pinochet and the end of immunity” in Temple International and Comparative Law Journal, 14 (Fall 2000): 263; and Hasson, A., “Extraterritorial Jurisdiction and Sovereign Immunity on Trial: Noriega, Pinochet and Milosevic: Trends in political accountability and trans-national criminal law” in Boston College International & Comparative Law Review 25 (2002): 125.Google Scholar

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26 Charney, J. “Transnational corporations and developing public international law” in Duke Law Journal (1983): 766.Google Scholar

27 Forcese, C. “ATCA's Achilles heel: Corporate complicity, International Law and the Alien Tort Claims Act“ in Yale Journal of International Law 26 (2002): 487.Google Scholar

28 See the case of Eastman Kodak Co. v. Kavlin, where the plaintiff was involved in a contractual dispute with a Bolivian company and claimed a conspiracy on the part of the firm and the Bolivian authorities to imprison him. The District Court observed that “it would be a strange tort system that imposed liability on state actors but not on those who conspired with them to perpetrate illegal acts through the coercive use of state power.” 978 F. SuPp. 1078 (S.D. Fla. 1997).Google Scholar

29 The corporation, at times, could be seen to be an accomplice with the regime that actually carries out the abuses. In this regard, the International Criminal Tribunal for Yugoslavia has found that an accomplice is guilty if “his participation directly and substantially affected the commission of that offence through supporting the actual commission before, during, or after the incident. The court furthermore required that the defendant act with knowledge of the underlying act.” Quoted in Ratner, S.R. “Corporations and human rights: A theory of legal responsibility” in Yale Law Journal 111 (2001): 443, 501.Google Scholar

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31 Id. The authors also note that, although corporations are not bound by the UDHR, a number of them are responding to the societal condemnation that arises from violating it by incorporating “an explicit commitment in their business principles” to upholding human rights.Google Scholar

32 Ratner, S.R. “Corporations and human rights: A theory of legal responsibility” in Yale Law Journal 11 (2001): 443, 492.Google Scholar

33 Boven, T. Van Study Concerning the Right to Restitution, Compensation and Rehabilitation for Victims of Gross Violations of Human Rights and Fundamental Freedoms, U.N. GAOR 4th Comm., 45th Sess., Provisional Agenda Item 4, para. 57, U.N. Doc. E/CN.4/Sub.2/1993/8 (1993).Google Scholar

34 See UN Commission on Human Rights document E/CN.4/2000/62 of 18 January 2000.Google Scholar

35 In the decision Prosecutor v. Tadic IT-94-1-A (July 15, 1999) the tribunal considered international principles for attributing actions of private actors to state actors. The tribunal held that a state can be held responsible because of its request to a private individual to discharge tasks on its behalf. (Judgment of the Appeals Chamber, at para. 119).Google Scholar

36 Parker, K. “Compensation for Japan's World War II rape victims” in Hastings International & Comparative Law Review 497 (1994): 502.Google Scholar

37 Another more recent example is one in which the U.S. government agreed to pay $5,000 and issue an apology to 2,200 Latin-American Japanese who were removed from Latin America during WWII and held in internment camps in the U.S. This resulted from a settlement agreement arising out of the case, Mochizuki v. United States No. 97-924C, 41 Fed. Cl. 54 (1998). See Saito, N. T. “Justice held hostage: U.S. disregard for international law in the World War II internment of Japanese Peruvians: A case study” in Boston College Law Review 1998 (December): 275.Google Scholar

38 630 F.2d 876, 880 (2nd Cir. 1980).Google Scholar

39 Ibid. at 890.Google Scholar

40 Reported in 9 Human Rights Law Journal 212 (1988)Google Scholar

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42 See Bazyler, M. J. “The Holocaust Restitution Movement in comparative perspective” in Berkeley Journal of International Law 20 (2002): 11.Google Scholar

43 Bazyler, M.J. o.c., 11.Google Scholar

44 Bazyler, M.J. o.c., 11.Google Scholar

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47 Filartiga v. Pena-Irala, 630 F.2d 876 (2nd Cir. 1980) where the court found that “deliberate torture perpetrated under color of official authority violates universally accepted norms of the international law of human rights, regardless of the nationality of the parties. Thus whenever an alleged torturer is found and served with process within United States borders, the ATCA provides jurisdiction.” 630 F.2d 876, 880 (2nd Cir. 1980).Google Scholar

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50 Filartiga v. Pena-Irala, 630 F.2d 876 (2nd Cir. 1980).Google Scholar

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53 Smith Kline & French Labs v. Bloch, 2 All E.R. 72, 74 (Eng. 1983).Google Scholar

54 These include the Torture Victims Protection Act, the Foreign Sovereign Immunities Act (FSIA), and terrorism laws. In January 2004, a federal judge in Connecticut ordered the Islamic Resistance Movement,(Hamas) to pay $116 million in damages for the deaths of an American citizen and his Israeli wife near the West Bank in 1996 under the Anti-Terrorism Act of 1991. The suit also names the Palestine Liberation Organisation and the Palestinian Authority as defendants. Those groups allegedly provided a haven and operational base for Hamas, which is responsible for many of the suicide bombings in Israel. “Judge orders Hamas to pay $116 million.” Washington Post, January 28, 2004.Google Scholar

55 630 F.2d 876, 880 (2nd Cir. 1980).Google Scholar

56 Ramsey, D.M. “Multinational corporate liability under the Alien Tort Claims Act: Some structural concerns” in Hastings International & Comparative Law Review, 24 (2001): 361.Google Scholar

57 Ibid. at 364.Google Scholar

58 These include forum non conveniens, international comity, act of state, and the political question doctrines.Google Scholar

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60 Iwanowa v. Ford Motor Co., 67 F. Supp. 2d 424, 489-90 (D.N.J. 1999).Google Scholar

61 70 F.3d 232 (2nd Cir. 1995). Here the plaintiffs were Croat and Muslim citizens of Bosnia-Herzegovina. They sued the leader of the other forces for having committed gross human rights violations such as genocide and war crimes. See also Lu, J. “Jurisdiction over non-state activity under the Alien Tort Claims Act” in Columbia Journal of Transnatational Law, 35 (1997): 531.Google Scholar

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63 At 239.Google Scholar

64 Doe v. Unocal Corp., 2002 U.S. App. LEXIS 19263 (9th Cir. September 18, 2002) at 32-33.Google Scholar

65 963 F. Supp. 880, 885 (C.D. Cal. 1997).Google Scholar

66 Id. at 36.Google Scholar

67 507 U.S. 349 (1993).Google Scholar

68 107 F.3d 720 (9th Cir. 1997).Google Scholar

69 Schrage, E. “A long way to find justice: What are Burmese villagers doing in a California court?” Washington Post, July 14, 2002.Google Scholar

70 Coyle, Marcia in the National Law Journal on 6 October 2003, wrote: “An attempt by the Bush administration and the business community to halt federal court litigation against corporations sued for human rights violations abroad appears to have suffered a major blow in the 9th U.S. Circuit Court of Appeals.”Google Scholar

71 National Law Journal, June 2003. http://www.law.com/jsp/article.jsp?id=1052440857507.Google Scholar

72 The Independent, December 18, 2003.Google Scholar

73 Financial Times, June 20, 2003.Google Scholar

74 The Washington Post, May 29, 2003. http://www.washingtonpost.com/wp-dyn/articles/A55921-200May29.html.Google Scholar

75 Richman, Josh “Bay area family wins Chilean ‘atrocity’ suit.” Oakland Tribune, October 16, 2003.Google Scholar

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78 In Iwanowa v. Ford Motor Co. 67 F. Supp. 2d at 433-34. The Court found that the Torture Victim Protection Act of 1991, 28 U.S.C. 1350, which has a 10-year statute of limitations, was the most comparable statute to the ATCA. See Iwanowa at 462.Google Scholar

79 US Senate report S.Rep. No. 249, 102d Cong., 1st Sess., (1991) 5.Google Scholar

80 US Senate report S.Rep. No. 249, 102d Cong., 1st Sess., (1991) 11.Google Scholar

81 518 A.2d 423, 425 (D.C. App. 1986).Google Scholar

82 886 F. Supp. 162, 191 (D. Mass. 1995).Google Scholar

83 164 F.2d 767 (2nd Cir. 1947).Google Scholar

84 At 769. This statement is reproduced in Forti at 1550.Google Scholar

85 At 1550.Google Scholar

86 See Forti v. Suarez-Mason, 672 F. Supp. 1531, 1549 (N.D. Cal. 1987).Google Scholar

87 176 F.R.D. 329, (C.D. Cal. 1997).Google Scholar

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91 Bazyler, M.J. o.c., 11.Google Scholar

92 Bazyler, M.J. o.c., 11.Google Scholar

93 Even at that time, questions relating to statutes of limitations were being asked. For example, Oliver Wendell Holmes asked, “What is the justification for depriving a man of his rights, a pure evil as far as it goes, in consequence of the lapse of time?” W. Holmes, O. Jr., “The path of the law” in Harvard Law Review, 1897, 10, 457, 476. This issue will be explored later in more detail.Google Scholar

94 It is a highly controversial issue. See Tracinski, R.W.“America's ‘Field of the Blackbirds': How the campaign for reparations for slavery perpetuates racism” in Journal of Law and Society, 3 (Winter 2002): 145.Google Scholar

95 At 1105. Cited in Aiyetoro, A. A. “The development of the movement for reparations for African descendants” in Journal of Law in Society 3 (Winter 2002): 133.Google Scholar

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98 See Ngcobo and others v. Thor Chemical Holdings Ltd. and another, [1995] TLR 579; Sithole and others v. Thor Chemical Holdings Ltd. and another, [1999] TLR 110.Google Scholar

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100 Evans, Roband MacAskill, Ewen “‘Tricked’ islanders sue UK for millions.” The Guardian, November 1, 2002.Google Scholar

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102 Redfern, Paul “Colonialism: Britain faces lawsuits.” The East African (Nairobi) January 26, 2004 Google Scholar

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104 The Terex claim was later dropped, at least temporarily. See UN Integrated Regional Information Network, September 21, 2001).Google Scholar

105 Various strategies have been attempted to claim reparations for the atrocities committed against the Herero people. Speaking at the commemoration of Herero Day at Okahandja in 1999, Chief Riruako stated: “On the threshold of the new millennium the Hereros, as a nation, have decided to take Germany to the International Court for a decision regarding reparations. We also warn the Namibian Government not to stand in our way as we explore this avenue to justice.” Each year in August, the Hereros come together in memory of their fallen heroes who died during the 1904-1907 Herero-German war. See Maletsky, C. “International court dashes Hereros’ reparation hopes” in The Namibian, September 8, 1999.Google Scholar

106 Chief Riruako has expressed dismay at the Namibian government's lack of interest in the Herero case, stating that: “For the (Namibian) government or any one to say, ‘I'm not part of it’ … must be nuts.” See Maletsky, C.and Mokopanele, T., “SA refuses to consider reparation for Hereros.” Business Day, September 28, 2001.Google Scholar

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109 Maletsky, C. “Hereros temporarily drop claim in $2bn suit.” Business Day, September 20, 2001.Google Scholar

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111 “Reparations not on the table.” The Namibian, August 31, 2000.Google Scholar

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