measure of satisfaction”.78 In the present case, the Court considers that the present Judgment constitutes a sufficient form of satisfaction, and that there is, therefore, no need for the Respondent State to make a public apology. 229. With regard to the request for an independent and impartial investigation into the alleged facts in order to establish individual criminal liability and prosecution of the perpetrators, the Court observes that the national and international commissions of inquiry established in the aftermath of the 2006 events helped uncover the truth and prosecute a group of State officials as well as officials of TRAFIGURA and other companies. However, the MoU signed between the Respondent State and TRAFIGURA, on 13 February 2007, prevented the prosecution some of these individuals. 230. The Court notes that any “reparation programme must also operate in coordination with other judicial measures. When a reparation programme is established in the absence of other judicial measures, the services it provides can be considered as a price through which an attempt is made to buy the silence and acceptance of the victims and their families. It is, therefore, very important to ensure that reparation efforts are coordinated with other judicial initiatives including criminal prosecutions to punish the perpetrators, truth-telling and institutional reform.79 231. The Court recalls, as established above, that the individuals and entities involved in the waste dumping enjoyed impunity as a result of the MoU. The said impunity was enshrined in immunity from prosecution granted to all individuals and entities involved, of whom only two TRAFIGURA officials were sentenced to prison terms before being released and allowed to leave the territory of the Respondent State. It follows, therefore, that other 78 Mtikila v. Tanzania (reparations), supra, § 45; Guéhi v. Tanzania, supra, § 194 and Thobias Mang'ara Mango and another v. United Republic of Tanzania, ACtHPR, Application No. 005/2015, Judgment of 2 December 2021 (merits and reparations), § 106. 79 Economic and Social Council, Protection and promotion of human rights - Impunity - Report of the Independent Expert to update the Set of Principles for the protection and promotion of human rights through action to combat impunity, Diane Orentlicher, 18 February 2005. 56

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