A Brief History of Ethiopia
Ethiopia is Africa’s oldest independent country and it is the second largest in terms of population. Unlike a great number of other African countries, Ethiopia was never colonized in the fullest sense of word; it was only occupied by Italy for 5 years during WWII. In 1936 Mussollini’s forces over took Addis Ababa and over the next few years put down a number of uprisings and killed a large number of young Ethiopian intellectuals. In 1941 Ethiopia regained independence and the leader Haile Selassie was reinstated. Since then Ethiopia has gone through a long period of significant transition that included internal fighting, famine and the border war with Eritrea. 
A referendum held in 1993 resulted in the adoption of the Federal Democratic Republic of Ethiopia (“FDRE”) Constitution in December 1994. Ethiopia's new government, led by Prime Minister Meles Zenawi, claimed to usher in a new era of political transparency and peace. The Constitution established nine regional states (known as Kililoch), based on language, culture and settlement patterns of the various nations, nationalities and peoples. Ethiopia’s federal system allows greater freedom and recognition of the rights and diversity of its various groups which in the past were victims of abuse and neglect. Under the federal system, states (Kililoch) are granted the status of a nation and granted the right to self-determination, without the right to secede. Self-determination generally includes the development of language, culture, history and administrative structure. State Councils are the highest level of State authority as well as State Administration which is the executive power. The State Council is the political authority dealing with regional powers, however, these powers are limited to those that are the competency of the central government, which include defense, foreign affairs and macroeconomic policy.
To Ethiopian minorities and observers in the international community the country seemed poised for democratic reform that would end decades of oppression. Ethiopia's new Constitution ambitiously sought to build a prosperous and inclusive Ethiopia that could survive the after effects of the legacy of the Italian occupation and internal fighting.
Since the ushering in of the FDRE Constitution, Ethiopia has continued to experience political hardships and oppressive leaders. The country was plagued with protests and political dissent by dissatisfied citizens leading the government to declare a state of emergency. With the ongoing protests, the response of the government has been to clamp down on opposition and limit the freedoms that are promised in the Constitution. In 2016 Human Rights Watch issued a report highlighting that the country’s leaders have continued a dangerous oppressive streak. The situation of the country is further worsened as it has been hit by one of the worst droughts in the history of the nation.
Type of Legal System
Ethiopia’s legal system is based on a continental model civil code. The independence of the judiciary is protected by the FDRE Constitution. All the judicial functions of the two levels - the federal and state - are left to the official courts. The federal and states courts have concurrent jurisdiction. The Federal Supreme Court may consider any matter federal, or state, and the state supreme courts have final authority over state matters. All courts, whether federal or state, are bound to follow the decisions made by the Federal Supreme Court as to a question of law. The court structures are regulated by the Federal Courts Proclamation No. 25/96. 
In law enforcement practices, three bodies are recognized under the Ethiopian justice system, having different functions; they are the Public Prosecution Service, the Federal Police, and the Federal Prison Commission. The Public Prosecution Office is formed under the Ministry of Justice. Each state has a state police with the power to investigate crimes limited under their territorial jurisdiction. Each state police may co-operate with the federal police, if necessary. The Federal Prison Commission is responsible for the management and administration of prisons and the rehabilitation of convicts. In the states, the State Prison Commission is responsible for implementing the administration of prisons and the rehabilitation of convicts within that state.
A significant part of Ethiopia’s legal system is governed by customary and religious laws. The FDRE Constitution provides in Article 34 (5) that: “This Constitution shall not preclude the adjudication of disputes relating to personal and family laws in accordance with religious and customary laws, with the consent of the parties to the dispute. Particulars shall be determined by law.” Article 78(5) of the Constitution also stipulates that: “Pursuant to sub-Article 5 of Article 34 the House of Peoples' Representatives and State Councils can establish or give official recognition to religious and customary courts. Religious and customary courts that had state recognition and functioned prior to the adoption of the Constitution shall be organized on the basis of recognition accorded to them by this Constitution.” It is clear from the above provisions that the jurisdiction of customary and religious courts is intended to be limited to personal and family law matters. Thus far the only religious courts that have been recognized by the law are Sharia courts that apply religious Islamic law. Article 34 (5) of the Constitution is a provision on plurality that makes it clear that parties are only subject to the jurisdiction of the religious courts if they both consent.
The Right to Council and Legal Aid
Article 20 (5) of the Constitution stipulates that “accused persons have the right to be represented by legal counsel of their choice, and, if they do not have sufficient means to pay for it and miscarriage of justice would result, to be provided with legal representation at state expense”.
The Ethiopian Human Rights Commission (“EHRC”) has established some 111 Free Legal Aid Centers across the country, with support from UNDP and other international donors. These centers have provided legal assistance to more than 12,000 people since 2010. The EHRC has signed agreements with 16 universities and NGOs to manage the centers, which also provide education and experience to law students. Some are strategically located at courts and prison compounds.
Sources of Defendant’s Rights
National Sources of Defendant’s Rights
Article 9 (1) of the Constitution states that the Constitution is the highest law of the land and all other laws that are in contravention with the law are invalid. International agreements and proclamations have the same status under the law as they are issued and entered into by the Federal government.
At the federal level, there is legislation that has been enacted to govern all matters related to criminal regulations at both state and federal levels. These are the Criminal Code of Ethiopia of 2004 and the Criminal Procedure Code of 1961 (“CPC”). Article 9 (4) of the Constitution encompasses that “all international agreements ratified by Ethiopia are an integral part of the laws of the country.”
International Sources of Defendant’s Rights
Ethiopia is a party to a number of international agreements that affect the rights of detained individuals. These include the Universal Declaration of Human Rights of 1948 (“UDHR”) of 1948, the International Covenant on Civil and Political Rights of 1966 (“ICCPR”), the Convention against Torture and Other Cruel, Inhumane or Degrading Treatment or Punishment of 1984 (“CAT”), and the African Charter on Human and People’s Rights of 1981 (“ACHR”). The intended effect of Section 9 (4) of the Constitution is that, in all its practice, Ethiopia must respect and protect the rights of individuals as they stand under international human rights regimes. In reality, this is not the case and violations have continued to plague the country. As of 2016, the government issued a state of emergency after some violent protests and this has resulted in some egregious violations of Ethiopia’s domestic law, as well as international human rights law.
Article 13(2) of the Constitution also provides that the fundamental rights and freedoms recognised under Chapter 3 of Constitution shall be interpreted in a manner conforming to the UDHR, the ICCPR and ICESCR and other international instruments adopted by Ethiopia. To ensure maximum enjoyment of human rights, the Constitution is interpreted in line with international law. Other international laws that are important in the criminal justice system ratified by Ethiopia include the Convention on the Elimination of All Forms of Discrimination against Women of 1979 (“CEDAW”) and the Convention on the Rights of the Child of 1989 (“CRC”).
Pre Trial Procedures
Under Article 19 (1) of the Constitution persons arrested have the right to be informed promptly and in a language they understand of the reasons for their arrest and of any charges against them. Article 26 of the CPC limits the police to only arresting individuals when there is a reasonable belief that the accused has committed a crime. Although not a precise standard, this ensures that the police to do not abuse their powers of arrest by arbitrarily detaining people when the evidence is clear they are not guilty. This is supported by Articles 53 and 54 of the CPC which stipulate that a warrant of arrest may only be issued by a court where there is an “absolute necessity” to ensure that the accused appears in court and that attendance “cannot be otherwise obtained.”
Human Rights Watch has reported that, in the wake of the declared state of emergency, human rights violations have become commonplace as police and military are detaining people without informing them of any charges and explanation of their overall rights. There are reports of mass arrest and prolonged detentions for unclear crimes.
The Right to Remain Silent
Article 19 (2) of the Constitution guarantees the right to remain silent. Article 19 (4) further states that “persons arrested shall not be compelled to make confessions or admissions which could be used in evidence against them. Any evidence obtained under coercion shall not be admissible.”
To discourage officers from eliciting inadmissible confessions from accused persons the law states that where a police officer is found to be guilty of a violation of the law, the police officer is subject to both civil and penal sanctions. Additionally, the courts do not allow into evidence confessions which have been obtained by force in terms of Article 19(5) of the Constitution. The courts have had an opportunity to consider this provision in the case of Abebe Esubalew vs Public Prosecutor, in which the accused had confessed to a crime under duress. He had been convicted in a lower court on the basis of that confession, however the Supreme Court reversed the conviction and reiterated that the constitution provided protections against accepting a confession that was coerced out of the client.
Yet despite the legal protections, the lived experience of Ethiopian citizens does not reflect these human rights standards. Although the right to remain silent is clearly enshrined in the Constitution, the practice is that the right is not adequately respected. In a disturbing report by Human Rights Watch in 2013 entitled “They Want a Confession: Torture and Ill-Treatment in Ethiopia’s Maekelawi Police Station” it was documented that torture is used to force confessions out of individuals in Ethiopian prisons. The HRW report documented how the police use torture as a means to gain confessions by forcing individuals to incriminate themselves, despite the fact that it is clearly a violation of Ethiopian national law as well as international law.
The right to appear before a court within 48 hours of arrest is enshrined in Article 19(3) of the Constitution. The 48 hours does not include the time it takes to travel to the police station. Once a person arrives at the police station, they are guaranteed the right to be informed of the charges.
With a warrant, authorities may detain persons suspected of serious offenses for 14 days without charge and for additional 14-day periods if an investigation continues. Several international organizations have noted how, in situations often involving political opponents, the right to appear within 48 hours is sometimes violated and there is little recourse available to the victims.
Over the years there have been reports of disappearances of political opponents and others accused of crimes. However, these numbers have been steadily declining and, according to the United States Country Reports on Human Rights for 2015, some of the people that are thought to have disappeared were actually found to be in prisons. The problem appears to be more of poor record keeping in prisons and failure to contact families rather than disappearances.
Right to be Granted Bail
Article 19 (6) of the Constitution states that “Persons arrested have the right to be released on bail. In exceptional circumstances prescribed by law, the court may deny bail…” This Constitutional provision is further governed by three provisions that impose separate regulation depending on the crime for which the accused is facing trial and highlight the exceptional circumstance in which bail may be denied:
a) Art.6 (3) of Vagrancy Control Proclamation 
“A person who is reasonably suspected of being a vagrant shall not be released on bail.” 
b) Art.4 (1) of the Revised Anti-Corruption Special Procedures and Rules of Evidence 
c) Art. 63(1) of the Criminal Procedure Code
“Whosoever has been arrested may be released on bail where the offence with which he is charged does not carry the death penalty or rigorous imprisonment for fifteen years or more and where there is no possibility of the person in respect of whom the offence was committed dying." 
Article 59 of the CPC indicates one may be denied bail in cases where the police investigation is not completed and the investigating officer applies for a remand for sufficient time to enable completion of the investigation. Similarly, Article 67 of the Criminal Code provides a list of factors that may influence the court’s decision on whether bail is granted, including cases where: the applicant is of such nature that it is unlikely that he will comply with the conditions in the bail bond; the applicant, if set at liberty, is likely to commit other offences, or; the applicant is likely to interfere with witnesses or tamper with evidence.
The question of whether or not legislation that completely denies bail is constitutional has been considered in the courts in Ethiopia. The Federal Supreme Court concluded that the right to bail is not absolute, and that the Constitution allowed for a limitation to bail where it was prescribed by law.
Rights of the Accused at all Time
Double Jeopardy is prohibited under Article 23 of the Constitution.
Article 22 of the Constitution stipulates that: “No one shall be held guilty of any criminal offence on account of any act or omission which did not constitute a criminal offence at the time when it was committed. Nor shall a heavier penalty be imposed on any person than the one that was applicable at the time when the criminal offence was committed.” This provision of the Constitution enshrines the non-retroactivity of criminal law that underlies the principle of legality. Art. 2 (1) of the Penal Code states that the principle of legality must be respected and Art 5 (1) states that there is to be no retroactive effect of criminal Law.
Presumption of Innocence
Article 20 (3) of the Constitution provides that “during the proceedings accused persons have the right to be presumed innocent until proved guilty according to law and not to be compelled to testify against themselves.” This provision is further entrenched in the CPC under Articles 141 and 142 which also assures an accused that they are presumed innocent until proven guilty.
The presumption of innocence is also found in the UDHR under Art. 11, the ICCPR under Art 14 (2) and the ACHPR under Art 7(1)(b).
The Criminal Code bars public hanging and any other inhuman methods of execution but leaves the method of execution for offences that carry the death penalty to be determined by the executive body responsible for the administration of the federal or regional prison where the execution will be carried out. The specific crimes that carry a death penalty are not listed; Article 117 of the Criminal Code states the death penalty may be issued “only in cases of grave crimes and on exceptionally dangerous criminals.”
Information on the use of the death penalty is particularly difficult to obtain for Ethiopia. Amnesty International notes that this results from a general lack of government transparency and legal restrictions on the work of human rights organizations within the country. However, the last known death sentence to be legally carried out was in 2007.
Article 28 of the FDRE Constitution provides that there shall be no period of limitation for persons charged with crimes against humanity per international conventions ratified by Ethiopia. Further, neither the legislature nor any other organ of the state has the power to pardon or give amnesty to such crimes; only the Head of State may commute the sentence from death to life imprisonment.
Fair Trial Rights
Right to Habeas Corpus
Article 177 (1) of the Civil Procedure Code stipulates that “an application for habeas corpus may be made to the High Court by any person restrained otherwise than in pursuance of an order duly made under this Code or the Criminal Procedure Code.” The procedures for submitting a writ of habeas corpus are detailed in the sections between Art 177 – 179 of the Civil Procedure Code. The right to habeas corpus are also entrenched under Art. 19 and 21 of the FDRE Constitution.
Right to a Fair Trial
Article 20 (1) of the FDRE Constitution provides: “Everyone charged with an offence shall be entitled to a public hearing before an ordinary court of law without undue delay; the trial may, however, be conducted in camera only for the purposes of protecting the private lives of the parties, public morals and moral security.”
The African Charter establishes the African Commission on Human and Peoples’ Rights (ACHPR). The Commission was inaugurated on 2 November 1987 in Addis Ababa, Ethiopia. Article 7 of the ACHPR Charter, said: “Every individual shall have the right to have his cause heard. This comprises: The right to be presumed innocent until proved guilty by a competent court or tribunal; The right to defence, including the right to be defended by counsel of his choice; The right to be tried within a reasonable time by an impartial court or tribunal.”
In addition, Article 280 of Ethiopia’s Criminal Code (2004) states: "Denial of Justice. Whoever, in time of war or occupation and in violation of the rules of public international law, deprives a civilian, a wounded person, a prisoner or an internee, of his right to be tried according to law guaranteeing him human treatment and the free exercise of his right to defend himself, or orders such deprival, is punishable with simple imprisonment from three years to five years”
However, in reality, the right to fair trial is not protected well. In 2014, some journalists were arrested on political charges and their lawyers reported that they were denied access to their clients. Previously, the ACHPR has urged the government to ensure people a fair and impartial trial.
Right to Appeal
Article 20(6) of the Constitution guarantees the right to appeal one’s matter to a competent judge. Article 78 of the Constitution directs the creation of three levels of state courts: the State Supreme Court (which also incorporates a cassation bench to review fundamental errors of state law), High Courts (or the Zonal Courts), and First Instance Courts (or the Woreda Courts). State Supreme Courts sit in the capital cities and have final judicial authority over matters of state law and jurisdiction; they can also exercise the jurisdiction of the Federal High Court if none exists in that state. Similarly, State High Courts sit in the zonal regions and can assert the jurisdiction of Federal First Instance Courts in addition to state jurisdiction. Arguably, while the federal courts are attempting to maintain control over the state courts, the state courts are trying to claim as much federal jurisdiction as possible. Under Article 78(2) of the Constitution, the House of Peoples’ Representatives can establish federal courts anywhere in the country “it deems necessary.”
In addition, Article 7.2(b) of the ACHPR Charter, provides the right to appeal: “The right to an appeal to competent national organs against acts of violating his fundamental rights as recognized and guaranteed by conventions, laws, regulations and customs in force.” The true application of this rule is hampered by the lack of free adequate legal assistance as well as poor record-keeping in the police stations as well as courts.
Rights in Prison
Conditions of Confinement
Article 21(1) of the Constitution stipulates that “all persons held in custody and persons imprisoned upon conviction and sentencing have the right to treatments respecting their human dignity.” Article 21 (2) further states that “all persons shall have the opportunity to communicate with, and to be visited by, their spouses or partners, close relatives, friends, religious councillors, medical doctors and their legal counsel.”
In 2007 the Ethiopian government adopted the Treatment of Federal Prisoners Council of Ministers Regulations No. 138/ 2007. The regulations established the basic principle: “The treatment of prisoners shall be based on the basic principles of: no discrimination on grounds of gender, language religion, political opinion, nation nationality, social status or citizenship; respect to their human dignity unless restricted by the penalties imposed on them; ensuring that the executions of penalties are educative and rehabilitative.”
Despite these provisions, Ethiopian prisons are notorious for not providing the best conditions for those incarcerated. According to the US Country Report, prison conditions are severe and have been found to be grave and threatening to the well-being of those incarcerated. There are challenges of severe over-crowding and very limited rations of food and clean water. Many prisoners are forced to have their meals and needs supplemented by their families.
Prison and pretrial detention center conditions remain severe and, in some cases, life-threatening. There are reports authorities beat and tortured prisoners in detention centers and police stations. Medical attention following beatings reportedly was insufficient in some cases.
Mental Health Care
According to a report by the Ministry of Health Care released in 2012, up to 62 percent of all inmates across Ethiopia suffered from some form of mental health challenges. These are caused by solitary confinement, starvation, over-crowding and inadequate health care services. Mental health services were provided for inmates by international organisations as the government struggles to meet the demands.
Women’s Rights in Prison
The Treatment of Federal Prisoners Council of Ministers Regulations No. 138/ 2007, Article 12 discusses the rights of women in prison. Women who have children who are under 18 months old may be allowed to live with their children in the prison if it is in the best interests of the child. The section instructs that if remaining with the mother in prison would “have an adverse physical or psychological impact” on the child, they must be placed with a close relative. Additionally, in the absence of a close relative, the Administration is required to “facilitate the possibilities” of finding another suitable placement for the child. In some cases, Ethiopian prisons have found orphanages to place children in where prison was no longer suitable and there was no relative available to take the child. The government has a duty to provide food and medical services for the child whilst he or she resides with the mother in prison. Pregnant women are also protected under this section and guaranteed the right to have additional food if a medical officer so recommends.
In reality, women’s prison cells in Ethiopia are overcrowded and cramped. According to the Ethiopian Women’s Human Rights Alliance’s UPR Submission, women are also tortured in prison, especially if they are arrested for political reasons. The government fails to supply sanitary towels to the women or any other form of medical necessities.
Right to Medical Care
The right to medical care was recognized by the law in Treatment of Federal Prisoners Council of Ministers Regulations No. 138/ 2007, however, in practice, there is very limited healthcare provided by the government to prisoners in Ethiopia. There is, however, a significant involvement of international organizations that assist in providing health care for those who are incarcerated.
- For a discussion on the secession of Eritrea and the Eritrean Revolution, see Dan Connell, Against All Odds: A Chronicle of the Eritrean Revolution with a New Afterward on the Postwar Transition (1997); Tekeste Nagash, Eritrea and Ethiopia: The Federal Experience (1997).
- See Federal Research Division, U.S. Library Of Congress, Ethiopia: A Country Study xxv-xxxvi (Thomas P. Ofcansky & LaVerle Berry eds., 1993), available at http://lcweb2.loc.gov/frd/cs/ettoc.html
- 9 National Regional states are Tigray, Afar, Amhara, Oromia, Somali, Benishangul-Gumuz, Southern Nations Nationalities and People Region (SNNPR), Gambella And Harari and two Administrative states (Addis Ababa City administration and Dire Dawa city council). The national regional states as well as the two cities administrative councils are further divided in eight hundred woredas and around 15,000 kebeles (5,000 Urban & 10,000 Rural)
- Matthew J. McCracken, Abusing Self-Determination and Democracy: How the TPLF Is Looting Ethiopia, 36 Case W. Res. J. Int'l L. 183, (2004)
- Article 78 of Constitution of Ethiopia
- Id. Art. 79
- Id. Art. 80
- as amended by Proclamations including 138/98 and 321/2003
- Article 4(1) of Proclamation No. 188/1999 stipulates that Federal Courts of Sharia have common jurisdiction over the following matters:” any question regarding marriage, divorce, maintenance, guardianship of minors and family relationships; provided that the marriage to which the question relates was concluded or the parties have consented to be adjudicated in accordance with Islamic law; any question regarding Wakf, gift/Hiba/, succession of wills, provided that the endower or donor is a Muslim or the deceased was a Muslim at the time of his death; any question regarding payment of costs incurred in any suit relating to the aforementioned matters.”
- Article 34 (5) “This Constitution shall not preclude the adjudication of disputes relating to personal and family laws in accordance with religious or customary laws, with the consent of the parties to the dispute. Particulars shall be determined by law.”
- http://www.ohchr.org/Documents/ProfessionalInterest/cedaw.pdf Ethiopia ratified CEDAW on 10 September 1981
- http://www.ohchr.org/Documents/ProfessionalInterest/crc.pdf Ethiopia ascended to the CRC on 14 May 1991
- It also guarantees the right to have the accused informed of his alleged crimes and legal rights in a language that he understands.
- Abebe Esubalew vs Public Prosecutor (Criminal Appeal File No. 173/78) in Selected Judgments Vol. 1, Federal Supreme Court Research and Publication Department, 1996, pp.328-335.
- The ICCPR, CAT and ACHR all have bans against torture and self incrimination.
- Art.59(2) of the Criminal Procedure Code
- https://www.amnesty.org/en/latest/news/2015/06/ethiopia-investigate-suspicious-murders-and-human-rights-violations-1/ see also, http://www.ohchr.org/EN/NewsEvents/Pages/DisplayNews.aspx?NewsID=16977&LangID=E
- Vagrancy Control Proclamation of Ethiopia No.384/2004
- A vagrant is defined as an able-bodied person who has no visible means of subsistence - Vagrancy Control Proclamation of Ethiopia No.384/2004
- Revised Anti-Corruption Special Procedure and Rules of Evidence Proclamation of Ethiopia no.434/2005
- A comprehensive list of corruption offences is provided in Title III, Chapter I of the FDRE penal code. A corruption offence, generally, is an act committed by a public servant with the intent to obtain for himself or to procure for another an undue advantage or to injure the right of another, directly or indirectly; or an act committed by any person with the intent to obtain for himself or another an undue advantage by giving or agreeing to give an undue advantage to a public servant
- One is suspected of a corruption offence punishable for not more than ten years does not guarantee his release on bail for he may be denied on grounds listed down under Article 4(4) of the Revised Anti-Corruption Special Procedure and Rules of Evidence.
- Serious punishments such as death penalty or rigorous punishment shall be passed only in cases of grave crimes and on exceptionally dangerous criminals – FDRE Criminal Code Articles 108 and 117
- That the conditions required under this provision for release on bail are met does not necessarily mean that the suspect will be released on bail for he may still be denied of bail on grounds provided under Article 67 of the 1961 Criminal Procedure Code of Ethiopia
- Art. 59. Detention. (l) The court before which the arrested person is brought (Art. 29) shall decide whether such person shall be kept in custody or be released on bail. (2) Where the police, investigation is not completed the investigating police officer may apply for a remand for a sufficient time to enable the investigation to be completed. (3) A remand may be granted in writing. No remand shall be granted for more than fourteen days on each occasion.
- Federal Ethics and Anti Corruption Commission v. Assefa Abrha et al (Criminal file No 7366, Federal Supreme Court, November 5, 2001) (unpublished)
- Bereket Alemayehu Hagos, (Non)retroactivity of Ethiopian Criminal Law, Abyssinia Law accessed at http://www.abyssinialaw.com/researches/category/19-criminal-law
- The Criminal Code of the Federal Democratic Republic of Ethiopia, art. 117(3), Proclamation No. 414/2004, May 9, 2005.
- It must be noted that although there are no records of capital punishment being executed, international human rights observers have noted with grave concern the number of extra-judicial killings that are taking place in the country.
- ACHPR 92: Resolution on the Situation of Human Rights in Ethiopia, Recalling Article 7 of the Charter which ensures the right to a fair trial and the Guidelines and Principles on the Right to a Fair Trial and to Judicial Assistance in Africa developed by the African Commission on Human and Peoples’ Rights. http://www.achpr.org/sessions/38th/resolutions/92/
- Information released by the Ministry of Health in 2012. 2010 the UN Committee Against Torture Reports.
- Ethiopia Ministry of Health Care 2012 reports: www.moh.gov.et/documents/26765/0/Annual+Performance+Report+2015/dddac759-77cd-43e8-a753-34f3222b1a0d
- The Ethiopian Human Rights Commission, Human Rights Protection Monitoring in Ethiopian Prisons: Primary Report 159 (July 2012), http://www.ehrc.org.et/LinkClick.aspx?fileticket=1uE7TO6QzbQ%3D &tabid=117.