# Verification workflow — EAC / CAE Habré The step-by-step procedure for verifying an EAC citation before it appears in an output. ## The principle No case-specific citation appears in an output until it has been verified against an authoritative source in the current conversation. Foundational instruments (Accord UA-Sénégal 2012, Statut des CAE, ICJ *Belgium v. Senegal*, ECOWAS Court *Habré v. Senegal*) may be cited from project knowledge when present. ## The fallback ladder 1. **forumchambresafricaines.org** — the principal mirror archive, first point of entry for any EAC document 2. **chambresafricaines.org** — the historical official site; intermittently unavailable, but check 3. **Wayback Machine** (`https://web.archive.org/web/*/chambresafricaines.org/*`) — fallback if both EAC sites are down 4. **legal-tools.org** — ICC Legal Tools Database mirror 5. **au.int** — for the Accord of 22 August 2012 and Trust Fund documents 6. **icj-cij.org** — for the *Belgium v. Senegal* judgment of 2012 7. **HRW** (hrw.org/habre-case) — Tier 1 in practice for procedural milestones (Reed Brody's archive) 8. **REDRESS, JusticeInfo.net** — for reparations-phase materials 9. **Academic literature** (Sarah Williams, JICJ 2013; *The President on Trial* OUP 2020; Nordic Journal of Human Rights 34(3) 2016) — for context and doctrinal commentary; never as authority for what the EAC has held 10. **Ask the user** if nothing verifies ## Capture these fields For every verified citation: - **Document type** — Ordonnance, Jugement, Décision sur les Réparations Civiles, Arrêt - **Chamber** — Chambre d'Instruction, Chambre d'Assises, Chambre d'Assises d'Appel - **Date** — exact date (the four key dates are 13 February 2015, 30 May 2016, 29 July 2016, 27 April 2017) - **Page or paragraph** — the EAC Trial Judgment of 30 May 2016 is voluminous (over 600 pages in French); use page references where paragraph numbers are not authoritative - **Civil/criminal dimension** — criminal disposition vs. civil/reparations disposition (the two are often co-located but legally distinct) ## Match the verification level to the claim - "Habré was convicted by the EAC in 2016" → existence verified - "The Trial Chamber found Habré responsible for crimes against humanity including rape and sexual slavery" → content verified - A direct quotation from the Trial Judgment or the Appeals Judgment → page or paragraph verified Never state a higher level than was actually reached. ## EAC-specific traps ### Trap 1 — EAC is NOT a Senegalese national court; nor is it a pure international tribunal The EAC is a **hybrid court** integrated into the Senegalese judicial system, **but with substantial international elements** (AU Accord, AU-appointed judges, international law applied alongside Senegalese law, jurisdiction grounded in universal jurisdiction obligations under treaty law). Common errors: - Calling the EAC "a Senegalese national court" — wrong; it is an internationalised chamber - Calling the EAC "a pure international tribunal" — wrong; it is integrated into Senegal's judicial system and applies Senegalese procedural law subsidiarily - Calling the EAC "an AU court" — wrong; the AU appointed judges but the court sits within Senegalese jurisdiction The accurate characterisation: **hybrid court created by AU-Senegal Accord, internationalised in composition and applicable law, integrated within the Senegalese judicial system, with universal jurisdiction grounded in treaty obligations**. ### Trap 2 — Trial Chamber (30 May 2016) vs Appeals Chamber (27 April 2017) — substantive differences The Trial Chamber convicted Habré on **all charges** including direct commission of rape of **Khadidja Hassan Zidane**. The Appeals Chamber **acquitted Habré of the direct commission of rape of Khadidja Hassan Zidane** while upholding the overall conviction for crimes against humanity (including sexual violence committed by others under Habré's responsibility). **This nuance is frequently lost** in summary citations. Care: - The overall convictions for crimes against humanity, war crimes, and torture **stand** - The conviction for **direct commission of rape** (one specific victim) **was reversed on appeal** - The life sentence **was upheld** on appeal - Habré's command/superior responsibility for sexual violence committed by DDS agents **stands** If your citation concerns the personal-direct-commission rape conviction, cite **the Trial Chamber of 30 May 2016**, but note the **Appeals Chamber reversal of 27 April 2017**. ### Trap 3 — Temporal jurisdiction strictly 7 June 1982 – 1 December 1990 The EAC's competence is limited to crimes committed during the **Habré presidency (7 June 1982 to 1 December 1990)**. Crimes committed before or after this period **fall outside the EAC's jurisdiction**. Common errors: - Citing EAC findings on conduct before 7 June 1982 (e.g., the prior conflict between FROLINAT factions) - Citing EAC findings on conduct after 1 December 1990 (e.g., Habré's exile in Senegal, the post-Habré transition) ### Trap 4 — Habré alone before the EAC (not "six co-accused") Some accounts mention "six co-accused" or describe the EAC as having prosecuted "Habré and his associates". This is **inaccurate**. - The EAC's Investigative Chamber initially considered charges against **other DDS officials** alongside Habré - However, **only Habré stood trial before the EAC** - The other identified suspects (Saleh Younous, Mahamat Djibrine, Khalil Djibrine and others) were tried before **Chadian national courts in N'Djamena in March 2015** (a separate proceeding, with significant procedural and political distinctions from the EAC) - The EAC's documentary corpus and judgments concern Habré **alone** When citing EAC findings, ensure they relate to proceedings against Habré, not against the Chadian-tried co-accused (which produced their own separate body of decisions — outside the EAC's jurisprudence). ### Trap 5 — "Hissein" vs "Hissène" The EAC judgments consistently use the spelling **"Hissein Habré"** (one 'n', without grave accent). Most French-language journalism uses **"Hissène"**. Both are encountered. The **judgments use Hissein** — that is the spelling for formal citation. ### Trap 6 — Reparations: trial chamber amounts vs appeal chamber total The Trial Chamber (29 July 2016) set **individual amounts by category** (20/15/10 million CFA per victim category). The Appeals Chamber (27 April 2017) confirmed the framework and fixed the **total** at 82.290 billion CFA francs. These are not contradictory but reflect **different stages**: - Trial Chamber: per-victim individual amounts - Appeals Chamber: aggregate total for 7,396 civil parties When citing the reparations sum, **be precise about which decision** you are citing. ### Trap 7 — Habré's death and the status of the criminal sentence Habré died on **24 August 2021** in Dakar. Legally: - The criminal sentence (life imprisonment) is **extinguished as a matter of personal execution** — he can no longer be imprisoned - The EAC's **substantive findings on his criminal responsibility remain authoritative** — Habré's death does not retroactively reverse the conviction - The **reparations obligation transferred to the AU Trust Fund** continues — though execution has been minimal due to lack of recoverable assets Common error: stating that "Habré's death closed the case". This is **partially accurate** (for criminal execution) and **partially inaccurate** (for the substantive record and the reparations obligation). ## Translation discipline EAC proceedings were conducted in **French** — the official language of Senegalese courts. **The French version of all EAC decisions is authoritative**. English translations (by HRW, JusticeInfo, scholarly publishers including Oxford University Press) are **unofficial and should be identified as such**. For a quotation in an English-language work, cite the French original and provide an unofficial English translation identified as such. Some witness testimony was given in Chadian Arabic or local Chadian languages (Sara, Hadjarai, others) with interpretation. The procedural record reflects this; substantive citations should be to the French judgment text. ## Partial verification is acceptable if disclosed If you can confirm the existence and substance of a passage but not the exact page or paragraph, the honest output says so. Disclosed partial verification is acceptable; silent overstatement is not. --- ## Reading the source document directly (the top of the ladder) The most reliable verification is reading the **actual document**, not a website's search snippet. Put this above everything else: **Rung 0 — work from the document itself when it is available.** Official tribunal sites frequently block automated fetching (HTTP 403), so a judgment can be public yet still unreachable by a direct fetch. Two ways to reach the text anyway: - **The user supplies it** — an uploaded PDF or pasted pages can be read directly, reaching paragraph-level verification. A practitioner working on a matter usually already holds the document; ask for it. - **A retrieval tool reads it** — where a document-retrieval tool or MCP server is available (one that fetches and extracts PDF text, with a fallback ladder), prefer it over a raw fetch. Only when the document cannot be obtained do you fall back to the search ladder above — and then you state the ceiling honestly. ## Site-search results are leads, not content A result from a site-search index — or a "synthesis" of search snippets — establishes at most that something **exists**. It is **never** content- or paragraph-level verification. Treat it as a lead to confirm against the document, and label it as such. Two recurring traps: - **Transliteration / OCR garbling.** Names and acronyms get corrupted (for example, an Arabic acronym surfacing as "KARA" where the source has "RADA/RADAA"). A name or acronym that appears only once in a snippet is a red flag — do not assert it. - **Relational claims.** Who is whose subordinate, associate, superior, or co-perpetrator is the detail a synthesis most often gets inverted. Never assert a relationship from a snippet; it requires the document.