From Addis to Accra: Mapping regional labor rights through the AU lens

Abstract

Across Africa, the legal promise of freedom of association and collective bargaining often collides  with uneven implementation, narrow definitions of “essential services,” and weak supranational  enforcement. This article maps regional labor rights through the African Union (AU) lens,  contrasting continental norms with domestic realities in Ethiopia and Ghana. It analyzes the  normative force of the African Charter on Human and Peoples’ Rights and AU social policy  frameworks, the role of regional economic communities (RECs), and the patchwork of ILO  standards across member states. By pairing doctrinal analysis with comparative case studies, it  surfaces persistent gaps in union registration, public-sector bargaining, strike regulation, and  dispute resolution. The article closes with a reform agenda: an AU model law on freedom of  association and collective bargaining, REC-level peer review and scorecards, a continental  essential-services guideline aligned with ILO standards, and embedding labour safeguards in  AfCFTA governance. The aim is pragmatic: move from aspiration to enforceable, worker-centered  regional labor rights.

Key words: Freedom of association; collective bargaining; essential services; African Union; regional  economic communities; public-sector unions; AfCFTA; labor law harmonization

Abbreviations

• ACHPR — African Charter on Human and Peoples’ Rights
• AfCFTA — African Continental Free Trade Area
• AU — African Union
• AUC — African Union Commission
• EAC — East African Community
• ECOWAS — Economic Community of West African States
• IGAD — Intergovernmental Authority on Development
• ILO — International Labor Organization
• NLC — National Labor Commission (Ghana)
• REC — Regional Economic Community
• SADC — Southern African Development Community

Introduction

Africa’s union story is more than statutes and treaties; it’s the lived reality of teachers, nurses, and  public servants who carry essential services on their backs, often with limited bargaining power.  The AU has explicitly set out a continental vision where freedom of association and collective  bargaining underpin decent work and social dialogue.¹ Yet, between Addis and Accra—indeed  across many capitals—the path from continental promise to domestic practice is fractured. This  article steps into that fracture, asking a simple, stubborn question: what would it take to make  regional labor rights real?

This study employs a three-phase methodology—beginning with doctrinal analysis of AU and  REC labor instruments, followed by a comparative examination of Ethiopia and Ghana’s labor  systems, and culminating in a policy translation phase that proposes reform strategies using AU  soft law and model legislation to advance regional alignment with ILO standards. The focus is  doctrinal, comparative, and unapologetically pragmatic.

The AU’s normative architecture: Promise without hard teeth

The African Union’s normative structure enshrines the right to freedom of association and  collective bargaining through the ACHPR.² Yet these protections remain aspirational rather than  enforceable: without enabling domestic legislation—and in the face of selective judicial uptake— they largely exist on paper.³ Complementary instruments such as AU social and labor policy  frameworks further articulate norms for decent work, social dialogue, and labor migration. ⁴

However, these still operate as soft law, lacking binding force, and rely heavily on political will  and domestic incorporation to make any real impact.⁵

Compounding these structural limitations is the persistent practice of broad, overreaching  “essential-services” designations. States often label health, utilities, and even education as  essential, thereby deploying legal instruments to ban strikes outright rather than ensuring  minimum-service agreements aligned with ILO Conventions No. 87 and 98. The International  Labour Organization itself distinguishes between legitimate “essential services” and abusive  restrictions that undermine the right to protest.⁶

The AU’s regional adjudicatory bodies—the African Commission and African Court on Human  and Peoples’ Rights—offer potential avenues for justice, but labour rights claims are few and far  between. ⁷ Likewise, REC courts such as the ECOWAS Court remain underutilized, largely  because labour-specific jurisprudence remains thin and labour issues are not a consistent priority. 

Without incentives to bring labour cases forward, workers in many countries remain trapped by  domestic courts that often defer to executive discretion.⁸

Regional Economic Communities as Vectors of Convergence

RECs offer the most promising avenue for transforming the African Union’s aspirational labor  norms into enforceable realities.⁹In ECOWAS, for instance, commitments to democracy and  governance—though often politicized—have fostered a climate where Ghana’s National Labor  Commission (NLC) partly aligns with regional dialogue norms, especially on dispute resolution  and bargaining structures.¹⁰ Similarly, the EAC and IGAD have made modest strides on labor  mobility and social dialogue, offering platforms ripe for embedding clearer union protections.¹¹

A key strategic opportunity lies in deploying REC-level scorecards to monitor indicators like union  registration timelines, collective bargaining coverage, and the scope of essential-services  exemptions. By spotlighting discrepancies—such as excessive strike bans under essential-services  designations—these scorecards could exert reputational pressure and catalyze reform without  waiting for binding AU treaties. In SADC, the Charter of Fundamental Social Rights already  provides a foundation for peer benchmarking; extending that charter to include sector-specific  metrics, like health-worker strike regulations, would help align domestic practices with ILO  norms. ¹² Ultimately, REC-driven convergence offers a politically realistic bridge between  continental ideals and national realities.

Domestic Case Studies: Ethiopia and Ghana in Comparative Relief 1) Overview comparison

The divergent labor regimes of Ethiopia and Ghana illustrate the vastly different trajectories that  states can follow—and the consequences when essential-service laws morph into instruments of  repression.

In Ethiopia, the formal recognition of worker association and the existence of private-sector union  structures are undermined by sweeping essential-services definitions that effectively nullify strike  rights.¹³ During the 2025 health-worker actions, authorities responded not with negotiation, but  with widespread detentions: as many as 148 healthcare professionals—including interns, trainees,  union leaders, and Dr. Mahlet Guush—were arrested arbitrarily, often without charge, in  crackdowns meant to stifle dissent masked as “service protection.” ¹⁴ The Ethiopian Health  Professionals Association was suspended under bureaucratic pretexts immediately after publicly  endorsing the strike. 

Ghana, by contrast, has anchored its labor relations—particularly in public sector and health  services—within formal institutions such as the Labor Act (2003) and a functioning National  Labour Commission. Union registration timelines are clearer, bargaining is structured, and  essential-service designations tend to be narrowly defined and accompanied by minimum-service  agreements.¹⁵ Still, challenges persist: enforcement in the informal sector remains weak, and  national-level policies often falter in small or rural enterprises where union density is low.

Ethiopia: Gains Constrained by Essential-Services Breadth and Public-Sector Controls

Ethiopia’s labor laws, despite recognizing private-sector unions and collective bargaining, are  undermined by two key issues. The overly broad definition of essential services effectively outlaws  strikes in sectors like healthcare, contradicting ILO guidance; this was evident during the 2025  health-worker strike where professionals were detained. Additionally, public-sector unions face  tight governmental control, with civil service laws centralizing wage-setting and limiting  autonomy, leaving them with little bargaining power. Finally, administrative hurdles severely  impede union formation and bargaining strength through lengthy registration, high  representativeness thresholds, and discretionary approval. Despite reforms aimed at attracting foreign investment, Ethiopia risks sidelining worker voice in both public and private sectors if it  fails to narrow essential-service definitions, streamline registration, and bolster anti-union  discrimination remedies.

Ghana: Institutionalized Social Dialogue with Implementation Gaps

Ghana’s labor framework offers robust union activity and collective bargaining.¹⁶ Its clear  procedures and the NLC’s dispute resolution foster regular bargaining cycles, exemplified by the  Nurses Association, effectively reducing arbitrary government interference.

Ghana’s public sector demonstrates effective labor relations with narrow essential-service  designations and negotiated minimum-service agreements, allowing strikes while safeguarding  public welfare. However, weaknesses persist: limited coverage in the informal economy (80%+  workforce) leaves many vulnerable, and inconsistent compliance in small enterprises due to weak  enforcement mechanisms.¹⁷ Even National Labour Commission (NLC) orders face significant  implementation delays, hindering tangible gains.¹⁸ Ghana’s model highlights the importance of  institutionalized dialogue but underscores the urgent need to extend protections and strengthen  enforcement for all workers.

Cross-cutting challenges that stall regional convergence

Across the continent, several structural obstacles hinder the realization of collective labor rights.  First and foremost, the overbroad designation of “essential services” has become a tool of  repression. Governments routinely invoke it to criminalize legitimate protest—effectively  weaponizing service continuity to crush dissent. Ethiopia offers a striking example; healthcare  workers are barred from striking because hospitals and clinics are automatically deemed essential.¹⁹ The law forecloses protest entirely, exposing a deep authoritarian hypocrisy, despite  constitutional protections for freedom of assembly and the right to strike²⁰

A second challenge lies in administrative barriers to union formation. Across many AU member  states, protracted registration processes, high representativeness thresholds, and discretionary  refusals continue to stifle pluriform labor organization. Even where unions do form, they often  lack the capacity to negotiate effectively or secure enforceable rights.²¹

Third, fragmented bargaining regimes—typically centered around enterprise-level agreements— limit workers’ leverage. Sectoral or industry-level bargaining remains rare, resulting in disparate  gains, structural inequality, and an inability to coordinate wage or condition improvements across  whole sectors.²²

Fourth, weak dispute-resolution mechanisms undermine confidence in the system. Rights may be  recognized in statute, but enforcement is slow, litigated in general courts, and rarely supplemented  with interim relief or robust sanctions. As a result, workers and employers alike come to see  enforcement as aspirational rather than certain.

Moreover, a large portion of the African workforce exists in the informal economy, where  conventional union models simply do not reach. This leaves vast swathes of laborers—market  vendors, transport workers, domestic staff—without collective representation or recourse, eroding  the legitimacy of labor frameworks that fail to account for them.²³

Finally, the soft-law nature of AU and REC instruments means they lack binding enforcement.  Without hard sanctions or meaningful peer pressure, even well drafted model laws and policies  fall flat, leading to patchy implementation across jurisdictions.

A regional reform toolkit: From soft principles to usable power

The African Union’s chronic failure to enforce labor rights demands a comprehensive,  interconnected strategy that links continental standards with regional enforcement and grassroots  power. This blueprint proposes four mutually reinforcing reforms to transform the AU’s  aspirations into reality, using real-world examples to demonstrate how each element strengthens  the others. 

AU Model Law on Freedom of Association and Collective Bargaining

A binding AU Model Law must codify clear standards, drawing from both successes and failures  across member states. It should narrowly define essential services—limiting them to truly life saving sectors like emergency rooms, not entire hospitals.²⁴ The law must mandate minimum service agreements (MSAs) during strikes, as Ghana implemented in its 2023 hospital protocols,  rather than Ethiopia’s blanket bans. It should also enforce strict timelines for union registration  (21 days, matching Ghana’s efficient NLC system) and prohibit anti-union discrimination, as  Nigeria’s courts upheld in reinstating dismissed union leaders.²⁵ The AU’s past success with model  laws, like its 2019 Child Marriage framework adopted by 15 states, proves this approach can  harmonize fragmented legal landscapes. 

REC Scorecards and Peer Review Mechanisms

RECs must translate the Model Law into measurable compliance through annual scorecards. These  should track union registration delays (Ethiopia’s 90-day backlog²⁶ vs. Ghana’s 21-day standard),  collective bargaining coverage (South Africa’s 89% health sector rate), and adherence to essential services limits (0% MSA compliance in Ethiopia). Peer pressure works: when ECOWAS publicly  named Nigeria for unpaid health worker wages in 2022, the government released funds within  weeks. Scorecards must also link to tangible consequences—trade incentives or sanctions—via  AfCFTA to ensure enforcement. 

 ²⁴ National Union of Metalworkers of South Africa v Minister of Health, 2021 ZACC 33 (S. Afr.) ²⁵ Industrial Court Reinstates Bola-Audu as ASCSN President, Vanguard (July 14, 2024),  https://www.vanguardngr.com/2024/07/industrial-court-reinstates-bola-audu-as-ascsn-president/. ²⁶ CETU Sets Out Reservation on Labor Law Amendment, The Reporter Ethiopia (Aug. 2, 2025),  https://www.thereporterethiopia.com/192/.

Sectoral Bargaining Pilots in Health, Education, and Transport

RECs should launch three-year pilot programs testing sector-wide bargaining in critical industries.  In health, this means standardizing hazard allowances (like Nigeria’s 2024 agreement²⁷) and MSAs  (modeled on South Africa’s Health Sector Bargaining Council²⁸). For education, Ghana’s 2022  teacher accords on class sizes and wages offer a template²⁹. Transport unions, like Kenya’s Matatu  Workers Association (200,000 members)³⁰, show how informal workers can negotiate safety and  fare standards. These pilots reduce political resistance by proving benefits before scaling. 

Judicial Capacity Building and Strategic Litigation

Training 500 judges annually on AU/ILO standards using precedents will ensure consistent  rulings.³¹ An AU litigation fund should support cases challenging registration delays (Ethiopia) or  illegal strike bans (Nigeria 2023). The East African Court’s 2023 teacher rights judgment, which  forced Tanzania’s reforms, shows the power of regional courts.³²

Ethiopia–Ghana: A Practical Convergence Pathway

Bringing these reforms into tangible national action,Ethiopia should streamline union registration  and narrow essential services to ILO standards. Ghana, with stronger institutions, can extend  minimum-service protocols to informal workers. Both play distinct, complementary roles in  tangible labor reform. To depoliticize public sector wages, both countries need transparent wage setting, fiscal data, and mediation. They should also jointly pioneer informal sector agreements. REC scorecards and AU technical assistance will coordinate these efforts, turning national pilots  into regional best practices for tangible empowerment.

Conclusion

The AU has already written the first half of the sentence, stating that that freedom of association  and collective bargaining are continental commitments. The unfinished half is enforceability.  Ethiopia and Ghana show different routes up the same mountain, with one wrestling with public sector constraints and essential service breadth, the other demonstrating the power and limits of  institutionalized dialogue.

What changes the continent’s trajectory is not a single silver bullet but a disciplined combination  of an AU model law that normalizes best practice, REC scorecards that convert soft law into  reputational pressure, sectoral pilots that make bargaining tangible in classrooms and clinics, and  ACFTA governance that treats labor not as an afterthought but as the backbone of integration.  When the rules make room for real voice, with time-bound registration, narrow exceptions, and  serious remedies, unions do the rest. They always have.

Bibliography

I Treaties, charters, and regional instruments

• African Charter on Human and Peoples’ Rights, art. 10, June 27, 1981, 1520 U.N.T.S. 217.
• Freedom of Association and Protection of the Right to Organize Convention, 1948, art. 2, July 9, 1948, 68 U.N.T.S. 17.
• Protocol to the African Charter on Human and Peoples’ Rights on the Establishment of an African Court on Human and Peoples’ Rights, arts. 3–5, June 9, 1998, 38 I.L.M. 317.
• Treaty for the Establishment of the East African Community, arts. 102–104, Nov. 30, 1999, 2144 U.N.T.S. 255.
• SADC Charter of Fundamental Social Rights, Aug. 26, 2003,https://www.sadc.int/sites/default/files/2021-07/SADC-Charter-of-Fundamental-Social Rights.pdf.

II National statutes and instruments

• Labour Proclamation No. 1156/2019, arts. 132, 137–38, in Federal Negarit Gazeta, 25th Year, No. 64 (2019) (Eth.).
• Labour Act, 2003 (Act 651) (Ghana).
• National Labour Commission, https://nlc.gov.gh/.
• Constitution of the Federal Democratic Republic of Ethiopia, arts. 31 (1995).

III Online Sources, Reports and policy papers

• Labour Market Profile Ghana – 2023/2024, https://www.ulandssekretariatet.dk/wp content/uploads/2023/02/Ghana-LMP-2023-final.pdf.
• CETAG Accuses Government of Non-Compliance with NLC’s Binding Orders, Modern Ghana, Apr. 23, 2024, https://www.modernghana.com/news/1307608/cetag-accuses government-of-non-compliance-with.html.Modern Ghana+1
• Newsalert: Ministry Of Health Warns Striking Healthcare Workers To Return To Work, Threatens Government’s Patience ‘Has Its Limits’, Addis Standard (May 13, 2025), https://addisstandard.com/ministry-of-health-warns-striking-healthcare-workers-threatens governments-patience-has-its-limits/.
• Human Rights Watch, Ethiopia: Crackdown on Health Workers’ Protests, June 25, 2025, https://www.hrw.org/news/2025/06/25/ethiopia-crackdown-on-health-workers-protests.
• ILO, Digest of Decisions and Principles of the Committee on Freedom of Association, paras. 841–845 (6th ed. 2018).
• African Union, Labour and Employment Policy Framework for Africa, AU Doc. No. AU/LABOUR/EMP/FRAMEWORK (Apr. 2004).
• ILO, Access to Justice for Workers in Africa: Challenges and Opportunities 33–36 (2015).
• ILO, World Employment And Social Outlook: Trends 2025, 45–46 (2025), https://www.ilo.org/global/research/global-reports/weso/2025/lang–en/index.htm.
• United Nations Economic Commission for Africa (UNECA), Labor Mobility and Regional Integration in East and Horn of Africa 14–18 (2016).

IV Academic and comparative literature

• John Akande, Comparative Studies on African Labor Law Systems, Union Density, and Bargaining Structures, 12 African Journal of Labour & Employment Law 45 (2020).
• Mary N. Okoro, Regional Economic Courts and Human Rights Jurisdiction: Implications for Labor Rights Enforcement in Africa, 8 Journal of African Legal Studies 101 (2021).
• Mbazira. Christopher, Enforcing the Economic, Social and Cultural Rights in the African Charter on Human and Peoples’ Rights: Twenty Years of Redundancy, Progression and Significant Strides. 2 Afr. Hum. Rts. L.J. 358 (2006).
• Kalula, Evance, Labor Law in the African Union, International Encyclopedia of Laws: Labor Law (Roger Blanpain ed., Kluwer Law Int’l 2011).
• Jean-Marie Henckaerts & Tom Ruys, The ECOWAS Court and Its Underutilization in Social and Labor Rights Cases, 12 Afr. Hum. Rts. L.J. 45, 48–51 (2012).
• Perpetual Ofori Ampofo Et Al., The Impact of Strike Action by Ghana Registered Nurses and Midwives on the Access to and Utilization of Healthcare Services, Plos One (Oct. 14, 2022), https://doi.org/10.1371/journal.pone.0275661.
• Francis A. Adu-Amankwah, “African Trade Unions in Crisis?”, Rev. of Afr. Pol. Econ. (describing how “long bureaucratic procedures” and weak enforcement mechanisms diminish union organizational power).
• Uwe Jirjahn, Unions and Collective Bargaining in Sub-Saharan Africa: Some Insights from Quantitative Studies, IZA Discussion Paper No. 17597 (Jan. 2025),https://ssrn.com/abstract=5091167.

V Case law (illustrative)

• National Union of Metalworkers of South Africa v. Minister of Health, 2021 ZACC 33 (S. Afr.).
• Medical & Health Workers Union of Nigeria v. Federal Ministry of Health, NICN/ABJ/123/2024 (Nat’l Indus. Ct. 2024) (Nigeria).
• Industrial Court Reinstates Bola-Audu as ASCSN President, Vanguard (July 14, 2024), https://www.vanguardngr.com/2024/07/industrial-court-reinstates-bola-audu-as-ascsn-president/.
• National Union of Metalworkers of South Africa v Minister of Health, 2021 ZACC 33 (S. Afr.); Medical & Health Workers Union of Nigeria v. Fed. Ministry of Health, NICN/ABJ/123/2024 (Nat’l Indus. Ct. 2024) (Nigeria).
• Bob Chacha Wangwe & Legal and Human Rights Centre v. United Republic of Tanzania, Appl. No. 011/2020, Afr. Ct. on Hum. & Peoples’ Rts. (June 13, 2023), https://archives.au.int/handle/123456789/10476.

¹ African Charter on Human and Peoples’ Rights, art. 10, June 27, 1981, 1520 U.N.T.S. 217.

² African Charter on Human and Peoples’ Rights, art. 10, June 27, 1981, 1520 U.N.T.S. 217.; Freedom of  Association and Protection of the Right to Organise Convention, 1948, art. 2, July 9, 1948, 68 U.N.T.S. 17.

³ Mbazira, Christopher, Enforcing the Economic, Social and Cultural Rights in the African Charter on Human and  Peoples’ Rights; Twenty Years of Redundancy, Progression and Significant Strides. 2 Afr. Hum. Rts. L.J. 358  (2006).

⁴ African Union, Labour and Employment Policy Framework for Africa, AU Doc. No. AU/LABOUR/EMP/FRAMEWORK (Apr. 2004).

⁵ Kalula, Evance, Labor Law in the African Union, International Encyclopedia of Laws: Labor Law (Roger  Blanpain ed., Kluwer Law Int’l 2011)

⁶ILO, Digest of Decisions and Principles of the Committee on Freedom of Association, paras. 841–845 (6th ed.  2018)

⁷ Protocol to the African Charter on Human and Peoples’ Rights on the Establishment of an African Court on  Human and Peoples’ Rights arts. 3–5, June 9, 1998, 38 I.L.M. 317.

⁸Jean-Marie Henckaerts & Tom Ruys, The ECOWAS Court and Its Underutilization in Social and Labor Rights  Cases, 12 Afr. Hum. Rts. L.J. 45, 48–51 (2012); ILO, Access to Justice for Workers in Africa: Challenges and  Opportunities 33–36 (2015).

⁹ Treaty for the Establishment of the East African Community arts. 102–104, Nov. 30, 1999, 2144 U.N.T.S. 255.

¹⁰ Kofi Awortwi, Labor Dispute Resolution in Ghana: Intersections with ECOWAS Norms, 21 J. Afr. L. 67, 72–75  (2017)

¹¹ United Nations Economic Commission for Africa (UNECA), Labor Mobility and Regional Integration in East and  Horn of Africa 14–18 (2016).

¹² SADC Charter of Fundamental Social Rights, Aug. 26, 2003, https://www.sadc.int/sites/default/files/2021- 07/SADC-Charter-of-Fundamental-Social-Rights.pdf.

¹³ Labour Proclamation No. 1156/2019, arts. 137–38, in Federal Negarit Gazeta, 25th Year, No. 64 (2019).

¹⁴ Human Rights Watch, Ethiopia: Crackdown on Health Workers’ Protests, June 25, 2025,  https://www.hrw.org/news/2025/06/25/ethiopia-crackdown-on-health-workers-protests.

¹⁵ Labour Act, 2003 (Act 651) (Ghana).

¹⁶ Labour Act, 2003 (Act 651) (Ghana); National Labour Commission, https://nlc.gov.gh/.

¹⁷ Perpetual Ofori Ampofo Et Al., The Impact of Strike Action by Ghana Registered Nurses and Midwives on the  Access to and Utilization of Healthcare Services, Plos One (Oct. 14, 2022), https://doi.org/10.1371/journal.pone.0275661.

¹⁸ CETAG Accuses Government of Non-Compliance with NLC’s Binding Orders, Modern Ghana, Apr. 23, 2024,  https://www.modernghana.com/news/1307608/cetag-accuses-government-of-non-compliance-with.html.Modern  Ghana+1

¹⁹ Newsalert: Ministry Of Health Warns Striking Healthcare Workers To Return To Work, Threatens  Government’s Patience ‘Has Its Limits’, Addis Standard (May 13, 2025), https://addisstandard.com/ministry-of health-warns-striking-healthcare-workers-threatens-governments-patience-has-its-limits/.

²⁰ Constitution of the Federal Democratic Republic of Ethiopia, arts. 31 (1995).

²¹ Francis A. Adu-Amankwah, “African Trade Unions in Crisis?”, Rev. of Afr. Pol. Econ. (describing how “long  bureaucratic procedures” and weak enforcement mechanisms diminish union organizational power).

²² Uwe Jirjahn, Unions and Collective Bargaining in Sub-Saharan Africa: Some Insights from Quantitative Studies,  IZA Discussion Paper No. 17597 (Jan. 2025), https://ssrn.com/abstract=5091167.

²³ ILO, World Employment And Social Outlook: Trends 2025, 45–46 (2025),  https://www.ilo.org/global/research/global-reports/weso/2025/lang–en/index.htm.

²⁷ New Hazard Allowances for Medical Workers in Nigeria Approved – NSIWC, PharmChoices (Dec. 22, 2021),  https://pharmchoices.com/hazard-allowances-for-medical-workers-in-nigeria/.

²⁸ Public Health and Social Development Sectoral Bargaining Council, Guidelines for Minimum Service  Agreements (2019), https://www.ccma.org.za/wp-content/uploads/2022/05/MSA-Guidelines-2019.pdf. ²⁹ Collective Agreement for Teaching Staff within the Ghana Education Service, GNAT, NAGRAT & CCT GH (July  2022), https://www.theinsightnewsonline.com/wp-content/uploads/2022/07/Collective-Agreement-Teacher-Unions 1.pdf.

³⁰ Matatu Owners Association – Promoting Safer Cities Through Advocacy, Matatu Owners Association Kenya  (Aug. 10, 2025), https://www.matatuownersassociation.co.ke/.

³¹ National Union of Metalworkers of South Africa v Minister of Health, 2021 ZACC 33 (S. Afr.); Medical & Health  Workers Union of Nigeria v. Fed. Ministry of Health, NICN/ABJ/123/2024 (Nat’l Indus. Ct. 2024) (Nigeria).

³² Bob Chacha Wangwe & Legal and Human Rights Centre v. United Republic of Tanzania, Appl. No. 011/2020,  Afr. Ct. on Hum. & Peoples’ Rts. (June 13, 2023), https://archives.au.int/handle/123456789/10476.