The Prohibition of Torture and Ill-treatment in the African Human Rights System: A HANDBOOK FOR VICTIMS AND THEIR ADVOCATES Victims of human rights violations can also submit complaints to the sub-regional justice mechanisms, namely the ECOWAS Court of Justice, the EAC Court of Justice and the SADC tribunal, in an effort to obtain remedy and reparation. The ECOWAS Court of Justice has been the most progressive of these bodies in terms of reparation, making awards in specific and significant amounts. Though the Supplementary Protocol, which mandates the ECOWAS Court of Justice to consider complaints relating to alleged violation of human rights, does not provide for reparation, the Court has held that it can do so under article 19(1) of the 1991 Protocol of the Court, which allows it to apply the ‘body of laws as contained in article 38(1) of the Statute of the International Court of Justice’, including: a. b. c. d. international conventions, whether general or particular, establishing rules expressly recognized by the contesting states; international custom, as evidence of a general practice accepted as law; the general principles of law recognized by civilized nations; subject to the provisions of Article 59, judicial decisions and the teachings of the most highly qualified publicists of the various nations, as subsidiary means for the determination of rules of law. The ECOWAS Court has in its jurisprudence made several awards of reparation that are particularly noteworthy. In the case of Musa Saidykhan v. The Gambia, the complainant requested compensation in the amount of US$2 million. The Court, finding a violation of Articles 5, 6, and 7 of the African Charter, considered ‘the loss of job and… loss of earnings, illegal detention for 22 days as well as physical injury which no doubt would have caused him pain and suffering, in assessing the damages for the plaintiff’.513 The Court awarded the complainant damages in the amount of US$200,000. In the case of Hadijatou Mani Korua v. Niger, the ECOWAS Court awarded the complainant compensation in the amount of 10,000,000 Niger francs (equivalent to approximately US$20,500) for the slavery and related human rights violations she was subjected to over a period of nine years.514 In the case of Djot Bayi and 14 Others v. Nigeria and 4 Others the Court called on Nigeria to compensate the ten applicants who had been subjected to prolonged arbitrary detention in the amount of US$42,720 each.515 513 SADCT, Musa Saidykhan v. The Gambia, Suit No. ECW/CCJ/APP/11/07. 514 ECOWAS Court of Justice, Hadijatou Mani Koraou v. Niger, App. No. ECW/CCJ/APP/08/08. 515 ECOWAS Court of Justice, Djot Bayi & Others v. Nigeria & Others, App. No. ECW/CCJ/APP/10/06. 116