United Nations

International Covenant on
Civil and Political Rights

Distr.: General
15 December 2014
Original: French

Human Rights Committee

Communication No. 2026/2011
Views adopted by the Committee at its 112th session (7–31 October

GE.14-24387 (E)

Submitted by:

Bariza Zaier (represented by Philippe Grant
of the Swiss association TRIAL – Track
Impunity Always)

Alleged victims:

Rachid Sassene (husband of the author) and
the author herself

State party:


Date of communication:

10 December 2010 (initial submission)

Document references:

Special Rapporteur’s rule 97 decision,
transmitted to the State party on 18 February
2011 (not issued in document form)

Date of adoption of Views:

29 October 2014

Subject matter:

Enforced disappearance

Substantive issues:

Right to an effective remedy, right to life,
prohibition of torture and cruel or inhuman
treatment, right to liberty and security of
person, respect for the inherent dignity of the
human person, recognition as a person before
the law and unlawful interference with the

Procedural issues:

Exhaustion of domestic remedies

Articles of the Covenant:

Articles 2 (para. 3), 6 (para. 1), 7, 9, 10
(para. 1), 16 and 17

Article of the Optional Protocol:

Article 5 (para. 2 (b))

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