56. We note that even the applicability of the continuing offense doctrine, as a criminal law concept, requires extreme judicial circumspection. The doctrine is usually advanced by the Prosecution to avoid the running of the statute of limitations – see the United States of America case of State v Ganier, 227 Kan.670, 672 (1980). In this regard, the USA Supreme Court did, by this doctrine, create an exception to the general limitations rule by carving out the continuing offense doctrine – namely, that the statute of limitations for continuing offenses begins to run not when the elements of the offense are first met, but when the offense terminates – see the Supreme Court`s seminal decision of Toussie v the United States 397 US, at 115 (1970). Nonetheless, in that very same hallmark decision (at p.115), the Supreme Court recognized the ``inherent tension between the continuing offense doctrine and the statutes of limitations``. It, therefore, directed that the continuing offense doctrine `` be applied sparingly``. In his penetrating article: Easing The Tension Between Statutes of Limitations And The Continuing Offense Doctrine, 7 NW. J.L. and Soc. Policy, 219 at p.222 (2012), http://scholarlycommons.law.northwestern.edu/nj/sp/vol7/iss2/1, JEFFREY R. BOLES categorically and emphatically states that: “the [continuing offenses] doctrine is disfavored by the Supreme Court and should be applied only in rare circumstances……it circumvents the protections to dependants afforded by the statutes of limitations … it is part of a larger shift towards retributivism [ie proportionate punishment]…. [is] disruptive… [and needs] reforming and restoring order in this problematic area of jurisprudence”.` 57. As regards the doctrine of continuing violations as a civil (not criminal) concept, the principle of legal certainty, is equally upheld in the courts where issues of human rights are litigated. The courts have underscored the necessity, even in human rights litigation, for litigants in any society to canvass their rights prompty, at the earliest possible opportunity — thereby, to assure non-derogation of the accrued rights and relationships of other members of society. Hence, the generally applied principle of law and equity to the effect that: he who claims a right, must not (like Rip Van Winkle) sleep or slumber on his right. An example of this philosophy is reflected in Uganda’s 19