The Admissibility of Subregional Courts’ Decisions before the African Commission. .. 249 rights jurisdiction in the EACJ, but postpones its operation until a future protocol authorises the commencement of the human rights jurisdiction.52 In Katabazi v Secretary-General of the East African Community, the Court was seized with a case in which ugandan security personnel interfered with preparation of bail documents by surrounding Ugandan High Court and re­ arresting persons who were released on bail.53 The arrested persons were taken before a military General Court Martial which remanded them in custody.54 Although the Ugandan Constitutional Court ruled that the interference of the security personnel with the High Court was unconstitutional, the arrested persons were not released.55 The plaintiffs mainly invoked the violation of the EAC Treaty. The Court held that “jurisdiction with respect to human rights requires a determination of the Council and a conclusion of a Protocol to that effect.”56 Since both of those steps did not take place, the Court held that “this Court may not adjudicate on disputes concerning violation of human rights per se.”57 However, the Court has shown some judicial activism.58 It held that ‘the intervention by the armed security agents of Uganda to prevent the execution of a lawful court order violated the principle of the rule of law.’59 Actually, the EACJ upheld the right to liberty and claimed jurisdiction in human rights cases by framing its decisions in terms of treaty violations. in East African Law Society v Attorney-General of Kenya, the applicant challenged the procedure of amending the EAC Treaty on the ground that it did not consult the people.60 Triggered by earlier decisions of the Court, the amendment modified the Court’s structure by introducing an appellate division. The impact of the amendment was negative as it narrowed the jurisdiction of the Court and provided a time limit within which references by natural and judicial persons may be instituted before the Court. The Court held that ‘the lack of people’s participation in the impugned amendment process was inconsistent with the spirit and intendment of the Treaty.’61 In essence, the Court upheld the 52 Art 27 (2), EAC Treaty. and Others v Secretary-General of the East African Community and Another (2007) AHRLR 119 (EAC 2007), para 2. 54 Ibid, para 3. 55 Ibid,para 4. 56 Ibid, para 34. 57 Ibid. 58 Solomon T Ebobrah (2009), ‘Human rights development in sub-regional courts in Africa in 2008’ African Human Rights Law Journal Vol. 9, p. 315. 59 Katabazi case , supra note 53, para 54. 60 East African Law Society and Others v Attorney-General of Kenya and Others, Reference 3 of 2007 at 11. 61 Ibid, p. 42. 53 Katabazi