Accordingly, the Plaintiffs detention amounts to deprivation of his liberty within the meaning of Article 6 of the African Charter. On allegation of seizure of passport and demand for gratification: The Plaintiff further alleged that the Defendants Officers demanded a gratification of 300 CFA before he could be allowed to proceed on his journey. His inability to meet their demands, led to the seizure of his passport. This the Defendant also denied. Seizure is defined under the Black’s Law Dictionary 9th Edition as “the act or an instance of taking possession of a person or property by legal right or process, especially, in constitutional law, a confiscation or arrest that may interfere with a reasonable expectation of privacy.” Article 14 of the African Charter on Human and Peoples’ Rights’ provides: “The right to property shall be guaranteed. It may only be encroached upon in the interest of public need or in the general interest of the community and in accordance with the provisions of appropriate laws. Right to property generally implies that an owner is entitled to no interference in the enjoyment of his property, in particular, by the government. 18

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