that forced expulsion is a violation of Article 18 of the Charter, as a result of the dispersal of the families of victims.56 The Commission adopted the same position in Modise v. Botswana, by concluding that the deportation of the Complainant deprived him of his family and also deprived the latter of his support.57 179. In the case in point, the Commission has already concluded that the victims suffered restrictions with regard to their movement both within and without the country. Furthermore, the Complainant reports testimonies to prove that police officers seized the identity documents of Dioulas, thereby preventing them from freely moving from one region to another in Côte d’Ivoire. Therefore, some of the victims had no other choice but to acquire a « laissez-passer », the validity of which did not exceed one month. In such circumstances, there is no doubt, as alleged by the Complainant, that the persons concerned could not visit their relatives living in other regions of the country. Such a situation also involved a real risk of separation or dislocation of the family unit. The Commission concludes that the provisions of Article 18 of the Charter have been violated. Violation of Article 22 180. Under the said article, « 1) All peoples shall have a right to their economic, social and cultural development with due regard to their freedom and identity and in the equal enjoyment of the common heritage of mankind … ». While the Charter guarantees development as a right of the « peoples », the grounds raised by the Complainant allege a violation of both a right to « personal development » under the guise of the loss of a « life plan » and the right to the full development of the Dioulas. On the effect of a careful consideration of these grounds, the Commission considers that it is proper to clarify the contents of the right to development under the Charter, its application and the attendant obligations to be borne by the Respondent State. These clarifications will then allow for a determination of whether the facts presented have hindered the achievement of a « life plan » of the victims and consequently violated their right to development. 181. The Charter is a pioneer international instrument for the proclamation and guarantee of a right to development. Having said that, the most advanced political and legal recognition of this right at the international level was formulated in 1986 when the United Nations General Assembly adopted the See Amnesty International v. Zambia Communication 212/98 (2000) AHRLR 325 (ACHPR 1999) para 51. 57 See Modise v. Botswana op. cit. para 92. 56 58