On December 5, the African Court of Human and Peoples’ Rights (the Court) ruled in Konate v. Burkina Faso (full text unavailable) that Burkina Faso was in violation of Article 9 (freedom of expression) of the African Charter, Article 19 (freedom of expression) of the International Convention on Civil and Political Rights (ICCPR), and Article 44 (discriminating internal legislation) of the Economic Community of West African States (ECOWAS) treaty by having and enforcing legislation that criminalizes “defamation” in the press and that Mr. Konate’s appeal against his domestic conviction for criminal defamation will go forward.  According to a news article, the Court held that “violations of freedom of expression cannot be sanctioned by imprisonment” and that Burkina Faso must pass new legislation “that meets proportionality and necessity requirements . . . within . . . two years.”