3. The Legal and Human Rights Centre (hereinafter referred to as “LHRC”) is an NGO based in Dar es Salaam, United Republic of Tanzania. It was granted observer status before the Commission on 6 November 2000.4 4. The three afore-mentioned institutions are hereinafter referred to as “the Applicants”. They allege violation of several rights of persons with albinism (hereinafter referred to as “PWA”) within the territory of the United Republic of Tanzania. 5. The Application is filed against the United Republic of Tanzania (hereinafter referred to as “the Respondent State”), which became a Party to the African Charter on Human and Peoples’ Rights (hereinafter referred to as “the Charter”) on 21 October 1986 and to the Protocol on 10 February 2006. Furthermore, the Respondent State, on 29 March 2010, deposited the Declaration prescribed under Article 34(6) of the Protocol (hereinafter referred to as “the Declaration”), through which it accepted the jurisdiction of the Court to receive applications from individuals and NGOs. On 21 November 2019, the Respondent State deposited with the Chairperson of the African Union Commission, an instrument withdrawing its Declaration. The Court held that this withdrawal has no bearing on pending and new cases filed before the withdrawal came into effect one year after its deposit, in this case, on 22 November 2020.5 II. SUBJECT OF THE APPLICATION A. Facts of the matter 6. The Applicants assert that, the population of PWA in the Respondent State is estimated to be more than 200,000 and this is considered to be one of 4 Granted observer status at the 28th Ordinary Session of the African Commission on Human and Peoples’ Rights (23 October – 6 November 2000). 5 Andrew Ambrose Cheusi v. United Republic of Tanzania (judgment) (26 June 2020) 4 AfCLR 219, §§ 37-39. 3

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