246 Mizan Law Review Vol. 6 No.2, December 2012 In Manneh v The Gambia, the Court considered a case submitted against The Gambia by legal counsels of Chief Ebrimah Manneh, a Gambian journalist who was arrested without warrant by two officials of the National Intelligence Agency of The Gambia.22 The officials did not give any reason for his arrest. The plaintiff had been detained incommunicado. He had been detained for more than a year without any criminal charge. The counsels for the plaintiff submitted that the defendant violated Articles 4, 5, 6 and 7 of the African Charter. They requested the Court to order the defendant to release the plaintiff and pay him five million US dollars in damages. Although the defendant refused to make an appearance, the Court heard witnesses and found that Articles 2, 6 and 7(1) of the African Charter were violated.23 The Court also ordered the defendant to pay US$ 100,000 to the plaintiff as damages.24 In Koraou v Niger, the Court considered a case of Hadijatou Mani Koraou, a Nigerien woman who was sold at the age of 12 to a 46 years-old man as “the fifth wife” called sadaka for the sum of 240,000 CFA Francs.25 The sale was conducted according to wahiya practice which was prevalent in Niger and consisted of “acquiring a young girl, generally under the conditions of servitude, for her to serve both as domestic servant and concubine.”26 “The sadaka generally carries out the domestic chores and caters for the ‘master’” who can engage her in sexual relations at any time.27 The plaintiff had served her master for nine years and obtained a certificate of emancipation from him in 2005.28 However, the ‘master’ refused to let the plaintiff free even after she obtained certificate of emancipation.29 She escaped from her master and brought a case against him which led to a judgment that she had never been married to her master.30 While her civil case was being considered by appellate courts, the plaintiff was prosecuted for bigamy upon the complaint of the master.31 The plaintiff, her brother and her husband were sentenced to six months imprisonment and a fine, and they were incarcerated until they were released on appeal.32 22Manneh v The Gambia (2008) AHRLR 171 (ECOWAS 2008), para 5. para 41. 24 Ibid, para 44 25 Koraou vNiger (2008) AHRLR 182 (ECOWAS 2008), para 8. 26 Ibid, para 9. 27 Ibid, para 10. 28 Ibid, para 13. 29 Ibid, para 14. 30 Ibid, para 15-16. 31 Ibid, para 21. 32 Ibid, para 22-23. 23 Ibid,