Dioulas to ownership as a result of the denial of nationality. On the other hand, the grounds invoked tend to render insecure, the property of Dioulas who have been denied nationality. The Commission notes that in this regard under the provisions of Article 1 of Law No 98-750 of 23 December, 1998 on rural land tenure (Law on rural land tenure), « only the State, public communities and Ivorian natural persons are allowed to be owners » of a parcel of rural land. Article 26 of the same law enumerates a series of limitations which would have the effects of an expropriation against any « non-Ivorian » person. 171. As a result of these restrictions, since Dioulas are considered as « nonIvorians » in practice and by application of the law on nationality, they cannot lay claim to land which is part of the rural land tenure regime. They also run the risk of being expropriated of the land they owned prior to the entry into force of the Rural Land Act in 1998. Such is the case because the said law replaces the traditional and customary modes of proof of ownership through documentary modes. The lack of documentary proof ensures that the concerned land reverts to the State. The heirs of concerned persons can therefore only avail themselves of the right of ownership after a declaration is made to the public authority, with the same risk being run by their donor of having themselves expropriated for the benefit of the State or an Ivorian third party. 172. The Commission notes that in Mouvement Ivoirien des Droits de l’Homme (I), it concluded that the above-mentioned provisions of the Rural Land Act violate Article 14 of the Charter in that expropriation which arises out of their application is neither justified by a « public need » nor the « general interest of the community ».51 The Commission had also deemed as inadmissible, the argument of the Respondent State to the effect that the said Law has had limited effects since only 112 persons of which very few Africans were concerned. It appears that the Commission had considered as a violation of Article 14 of the Charter, the refusal of access to property on the basis of « origin ».52 However, it is essential to clarify the applicability and effects of these provisions of the Law and the jurisprudence of the Commission with regard to the Dioulas and other victims. 173. With regard to the Dioulas, the Commission notes that the Law uses the term « Ivorian ». Since this term is not qualified, reference should be made to the Law on nationality to determine the definition and contents. The Commission has already resolved the issue of the right of the Dioulas to 51 52 Mouvement Ivoirien des Droits de l’Homme (I) para 78. Op. cit. 55