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1526539 (accessed 20 May 2011). 3 C. C. Jalloh, `Michelot Yogogombaye v Republic of Senegal', 104 American Journal of International Law (2010): 6208, 620; S. P. Marks, `The Hissène Habré Case: The Law and Politics of Universal Jurisdiction', in S. Macedo (ed.), Universal Jurisdiction: National Courts and the Prosecution of Serious Crimes Under International Crimes, University of Pennsylvania Press (2004), p. 135. Brian Sang Y.K. This application came in the wake of earlier attempts at holding Hissène Habré to account for these crimes. In 2000, an attempt to prosecute him in Senegal stalled owing to provisions against retroactive application of criminal law in the Senegalese Constitution.4 An international arrest warrant and request for extradition for Hissène Habré was subsequently issued by a Belgian Court for the international crimes committed during his regime.5 However, Senegal neither prosecuted nor extradited Habré to Belgium, leading to a complaint of its violation of the United Nations Convention against Torture6 being instituted against Senegal before the United Nations Committee against Torture.7 Later on, Senegal's alleged violation of its obligation to prosecute or to extradite Habré to Belgium was the subject of an application before the International Court of Justice (ICJ).8 A subsequent decision
African Journal of International and Comparative Law – Edinburgh University Press
Published: Oct 1, 2012
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