HIGH COURT OF LESOTHO
Crown : Mr Mokuku
Accused : Mr Ntlhoki
by the Honourable Mr. Justice T. Monapathi on the 14th day of
Accused pleaded not guilty to a charge of murder. It was alleged that
on the 25th December 1989 at Ha Mphatlalatsane Sekonyela, in the
district of Mokhotlong the Accused intentionally killed Mokaka
Roelane (Deceased). Accused admitted before this Court that he shot
the Deceased who died on the same day. as a result.
who was a policeman at the material time had been armed with a
warrant of arrest Exhibit "A" against the Deceased. It was
not disputed that the warrant had been issued by the magistrate of
Mokhotlong because the Deceased had failed to attend a part-heard
case in which he had been charged with rape.
last day of hearing of the said rape case the Accused had been
allowed to look for his witness who would attend on the next day of
hearing. Accused had failed to attend and had not since attempted to
do so. It was not disputed that the Accused killed the Deceased on
this day when Accused was attempting to execute the said warrant
against the Deceased who was fleeing and resisting arrest.
commented during the application for discharge at the end of the
Crown case -there was a large body of evidence over which the Crown
and the Accused agreed and did not dispute. Centrally the Accused had
contended that he killed the Deceased in a justifiable homicide in
terms of section. 42(1) of Criminal Procedure and Evidence Act 1981
accepted, in my ruling in that application for discharge, that there
were cases where strictly speaking the Crown may be adjudged to have
"failed to present a necessary degree of evidence" the
Accused may not necessarily have to be discharged. One case is where
as in the instant case attendant circumstances were such that
"failure of justice could possibly result if the accused person
were to be discharged." See R v Herholdt And Others 1956(2) 722
at 723 C-D.
necessary for the Accused to place himself under the protection of
the Section 42(1) CP&E. Admitting that he killed the Deceased in
a justifiable Homicide
of the said section was not enough. I refused the application. In my
discretion I felt the Accused had an onus to demonstrate how he fell
under the protection of the said section. The result was that the
Accused himself testified under oath in his own defence. He became
the only witness for the defence.
Preparatory Examination (PE) had been held and completed on the 30th
May 1996 by the magistrate of Mokhotlong. Of the six witnesses led at
the PE the depositions of three witnesses were admitted by consent.
Matters admitted by Counsel included the post mortem report. The
admitted depositions were of PW 4 (Masianokeng Seoete). PW 5 (Phororo
Lejesa) and PW 6 (Det. Trooper Letsoepa).
mortem report was admitted and handed in by consent as aforesaid. It
showed that the cause of death was due to a single gun shot wound on
the left side of lower ribs. The doctor who examined the body (Dr
Schumech) was no longer in Lesotho. The wound on the Deceased was
described externally as:
"From blister and falling off down on the abdominal wall. Single
penetrating wound at the left side of the ribs. Single wound right
flank which might be at a place where the bullet left the body.''
deposition at PE showed that he identified the body of the Deceased
and that he was the one who reported the matter of Deceased's death
to his family after a search for Deceased. He testified that he saw
the Deceased's body carried to a mortuary
body did not sustain any further injuries along the way. The witness
before the doctor who performed a post-mortem examination. After that
body to his village where it was buried.
deposition was to the effect that after an alarm raised that there
was a chase involving two men. he met one of them. It was the Accused
in plain clothes who identified himself as a policeman and the one
who had just shot the Deceased. Accused had a short pants on. He went
on to show the witness where Deceased lay dead. The witness advised
the Accused to report to Chief Mahomed. The witness accompanied
Accused to that chief who wrote a report letter of the incident to
the chief of Tlokoeng. Then to Mapholaneng police post. He learned
that the Deceased's body was later removed by the police.
PW 6 who
was in the Criminal Investigation Department of Lesotho Mounted
Police was also a relative of the Accused and were at the same
station. He knew that Accused had gone for patrol on the 25th
witness became an investigating officer in the case of the Deceased's
death after he received a report from the Accused later in the day.
It was about the Accused's killing of the Deceased which Accused
reported in the presence of Warrant Officer Lechesa and the Sargent
Mokheleli. The Accused gave an explanation to the two police officers
about his killing of the Deceased with a revolver (Serial no. 452307)
PW 6 was
shown a revolver and four (4) shells of the 4.5mm type. These were
later exhibited in Court. During argument Mr. Mokuku raised the issue
that the empty shells could have been result of a shooting somewhere
else but not at the scene when Deceased was being chased. I thought
the issue was unfairly raised when Accused had not even been
challenged on it. As will be this Court's position I inclined, when
all circumstances were considered, to the Accused's version of this
aspect as being the more probable. The report given to the police
officers by the Accused included his possession of a warrant of
apprehension with which as he alleged he had been armed with when he
proceeded to seek to arrest the Deceased when the events leading to
his death followed. It was produced in Court and exhibited.
police ended up attending at the village where Deceased died and
reported themselves to the chief. They examined the Deceased's body
which lay "down the village on the edge of the fields and there
was a path nearby". The body was examined as to its clothing
which was later exhibited. A single entry wound was found "on
the left side of the abdomen." The witness did not know if the
gun was ever sent for ballistic tests.
following witnesses testified before this Court PW 1 Thabang
Rakholoane (who was PW 1 at the PE), PW 2 Monki Leoto (who was PW 3
at PE). As I observed
close of Crown case there was a large body of evidence over which the
Crown and the defence agreed and did not dispute. That is why Mr.
Ntlhoki very safely concentrated on discussing the Accused's version
in his address after close of defence case. That will be of more
interest later. Accused became the only witness on his own behalf. It
needs reminding that the test will still be whether or not his
version was reasonably possibly true or whether it will be proved to
be false and if false whether it was so beyond a reasonable doubt.
testified that on the day in question he was riding on Deceased's
horse after having drinks with the Deceased and other men. He was
going to his home when he met with a vehicle occupied by two men and
one of them said: "That is the man I am looking for. Mokaku!!.
The same man alighted from the vehicle. He thereupon attacked the
witness. He look his blanket, hat and the Deceased's horse. He must
have realized that the witness was not the person he was looking for.
who had alighted from the vehicle inquired about the whereabouts of
the Deceased. He was told where the Deceased was. He duly took the
direction given by PW 1. PW 1 had earlier in the day been drinking
with the Deceased. The witness went on to state that he went to his
home as he was tired. He identified the man who was looking for the
Deceased was the Accused before Court. I did not have any reason to
question any material aspect in this witness' testimony.
Monki Leoto testified that he knew the Deceased. On the 25th December
1989 he had been herding animals. The boys with whom he was herding
cattle alerted him to what they said was a boy chasing a man. He
identified the man being chased as Deceased while he was not able to
identify the other one who had a short pants on. PW 2 in his
testimony denied that he saw the two men get close to the point of
further testified that he observed the chase from the time the young
boys asked him to come and watch the chase. He had then heard a gun
report. He testified that after the sound of the gun discharge he no
longer saw the person being chased. He could only see the person
wearing a short pants who had been chasing. The witness also admitted
that due to the terrain there were occasions when both the Accused
and Deceased were out of sight. The witness however denied that there
was even a point when Deceased bent down to pick up stones nor threw
any stones at Accused.
witness admitted that he could have heard more than two gun reports.
That is precisely what he had testified to at the PE. Another witness
spoke of about five gun report (PW 2 Mamatono Polinyane at the PE).
Without pre-empting my observation on this aspect probabilities
pointed at the Accused having discharged the gun on four occasions
which was corroborated by the four shells which were handed to
Trooper Letsoepa. I had the impression that the PW 2's recollection
was dull and was compounded by his lack of sophistication. I found it
difficult to understand why the witness struggled to have observed
things which may in his community took for granted.
example the cardinal points. In any event he was not a lying witness.
story was straight forward and was mostly corroborated except that
the Deceased had picked up stones and threw any at the Accused by way
of fighting or fighting to resist arrest. Nor was there ever any
testimony suggesting that the Accused got so close to the Deceased to
the point of touching the Deceased physically to indicate that he was
Accused had been armed with a warrant of apprehension as alluded to
before. He proceeded to Deceased's place to effect his arrest.
Deceased was found to be absent at his place. Coincidentally one
other person was looking for Deceased. He could be that gentleman who
was later found with Deceased's horse.
took the direction of Mapholaneng where he failed to locate the
Deceased. On his way back from Mapholaneng Accused got information
that the Deceased might have been at Ha Ramonakalali. On his way to
Ha Ramonakalali Accused said he met a gentleman ho had in his
possession Deceased's horse. When Accused spoke to the gentleman he
was given direction leading to where Deceased could be found. Accused
there and then took away the horse, the blanket and the hat from the
man. It was not quite in issue whether the items were voluntarily
handed to the Accused.
took the directions suggested. He was then on horseback. At one point
was said to have become aware that it was the Accused who was in
possession of his horse. He thereupon took flight. Accused then gave
chase and in the process discharged three shots with his gun into the
air in order to warn or frighten the Deceased. He ended up catching
up with the Deceased who he even touched physically to indicate that
he had effected his arrest.
that this aspect of effecting arrest of the Deceased was not put to
any of the witnesses. Mr. Ntlhoki's reply when shown how important
and unfair this was to the Crown who had to anticipate this aspect of
the defence case was simple and glib. This I say considering the
total circumstances of the case.
that PW 2 who was the witness who could have had the opportunity to
vouch for having made any observation of the movements and chase had
consistently said he had at most occasions lost sight of the two
chasing gentlemen because of the terrain. So that putting the aspect
to the witness would have elicited nothing in response.
Mr. Ntlhoki's response was that inasmuch as he had before him PW 2
who could even testify to seeing the chase Counsel was only required
to put to the witness as much as was relevant to what the witness had
testified over. See Small v Small 1954(3) SA 434 (SWA) as quoted in
Phaloane v R 1980-84 LAC 72 at 77 F-J.
the answer was generally valid, I questioned the approach of Counsel
where at the close of the Crown case matters that constituted
Accused's defence or an important aspect of his defence could not
have been shown the Court because a proper witness (according to
Counsel's estimation) to put a version of the Accused had not come
up. Whatever the approach my understanding has always been that it is
desirable from the onset and ideally towards the first witness who
comes by. that the defence should indicate what its defence or total
version will be. Much as defence Counsel will almost always
reluctantly do so this approach will work in favour of the Accused in
other hand it becomes an unfortunate Court when a Court finds that at
the end of the Crown case it does not know what the case or the
version of the Accused will be. This showing of the Accused's defence
or likely version must always be disclosed as early as possible. It
does not matter what approach Counsel will adopt. It is a bad tactic
not to do so. I repeat that putting the Court in the knowledge what
the Accused's version will be can only work in favour of the Accused.
before Accused said that having been given guidance he rode the
Deceased's horse and having been so disguised as PW 1 he came upon
Deceased on the way. Deceased thereupon ran away. Accused testified
that he chased Deceased and during the chase fired three shots into
the air to warn him against being set in his ways.
went on to say that he later caught up with Deceased and even touched
physically on the shoulder to effect an arrest. Deceased then broke
loose and started running again before stopping to pick up stones
with which he started to pelt Accused. Accused safely ducked stones
and advanced. He stopped when he realized that Deceased had picked up
another stone and was definitely poised and aimed to hit Accused with
that stone. As to the fact that Accused felt that he had effectively
arrested raised a dimension that from then on the Deceased could have
been resisting arrest by his actions if the Accused is believed.
then said he would have had no option but to fire his gun in the
direction of the Deceased, since he could not at the time of seeking
to avoid the stone poised in his direction, aim accurately at the
lower part of the Deceased body, which he should have done. As he
demonstrated he even had to shield his face with his left hand to
anticipate a stone that would have been directed at his head. The
Deceased must as the Accused said have been at a distance of about
twenty paces away from the Deceased when Accused discharged his gun.
The Deceased slumped on the spot and lay supine. Accused afterwards
reported the incident as already stated elsewhere in this judgment.
raised the defence of Justifiable Homicide as envisaged in section
42(1) of the Criminal Procedure and Evidence Act of 1981 (CP&E).
His main reason fordoing so was that the Deceased was fleeing and
there was no other way to stop him except to kill him. In addition
having been armed with a warrant as aforesaid Accused was bound to
obey and execute such warrant in terms of section 34(1) of the CP&E.
was making difficult to arrest when Accused was already in hot
pursuit. I would add that in no way was it basically suggested that
the intended arrest had been unlawful for any reason. It ought to be
clear by now that in terms of Accused's testimony there was an
element of self-defence as in connection with the stone held by
Deceased and poised to strike.
to my comments about some aspects of the defence not having been put
to the witness and what appeared to be a genuine perception on the
part of Mr. Ntlhoki about the proper approach it cannot be as if the
Accused had the onus to prove that he acted in self-defence. On the
contrary the Crown had to prove that the Accused did not act in
self-defence. I would add that in no way was it basically suggested
that the intended arrest itself by the Accused had been unlawful for
section 42(1) of the CP&E which Mr. Ntlhoki said was similar to
the South African provisions in Criminal Procedure Act 1955 reads as
"42(1)When any peace officer or private person authorised or
required under this Act to arrest or assist in arresting any person
who has committed or is on reasonable grounds suspected to having
committed any of the offences mentioned in Part II of the First
Schedule, attempts to make the arrest, and the person whose arrest is
so attempted flees or resists and cannot be apprehended and prevented
from escaping, by other means than by the peace officer or private
person killing the person so fleeing or resisting such killing shall
be deemed justifiable homicide."
Ntlhoki submitted of the lack of certain requisites the above
provision in comparison
present South African provision of section 49(1) and (2) of Criminal
Act No. 51 of 1977 which reads:
"49 Use of force in effecting arrest -
(1) If any person authorized under this Act to
the attempt and cannot be arrested without the use of force; or
when it is clear that an attempt to arrest him is being made, or
resists such attempt and flees.
The person so authorized may, in order to effect the arrest, use such
force as may in the circumstances be reasonably necessary to overcome
the resistance or to prevent the person concerned from fleeing.
the person concerned is to be arrested for an offence referred to in
Schedule 1 or is to be arrested on the ground that he is reasonably
suspected of having committed such an offence, and the person
authorized under this Act to arrest or to assist in arresting him
cannot arrest him or prevent him from fleeing by other means than by
killing him. the killing shall be deemed to be justifiable
homicide." (My emphasis)
added that it would improper be interpret our section 42(1) in terms
of the requirements found in South African section 49(2) which has
other further requirements. As can be seen above there is no
essential difference in the two provisions except that the South
African one is much more elaborate. In addition I am persuaded that
the Lesotho provision can wisely be interpreted in terms of the South
African one to make interpretation of the former clearer and more
effective. I would use the words in the South African statute such as
"a particular form of words is used that has also been used in
different statutes to express the same idea or concept as that
expressed in the statute the Court is interpreting......".
Interpretation of Statutes. GE Devenish 1st Edition page 274. The
basis for doing so would even be more compelling such as where we
adopt the very persuasive South African precedents ".... on the
basis of sound legal reasoning and value judgment". See
Interpretation of Statutes page 274 (supra)
approach in interpretation is a constitutional one. It calls for an
attitude on the part of the Court which is consistent with an
obligation on the part of the Court to construe existing laws
(including customary law):
"with such modifications adaptations qualifications and
exceptions as may be necessary to bring them into conformity with the
section 156(1) of the Constitution of Lesotho.
Mokuku stressed that our section however requires that before a
person can be killed as a way of stopping him from fleeing, other
means which are less tragic should have been tried and should have
failed. One of them should have been to abandon chase and/or fire
warning shots. As Mr. Mokuku emphasized if the Accused saw no chance
of apprehending Deceased especially since he had lost his handcuffs
he should have let the Deceased go. And he should have returned to
his station and asked for backup from his colleagues to help him to
effect arrest of the Deceased who was being recalcitrant and
as Accused perceived.
present case the Accused claimed that he chased Deceased and fired
warning shots to try and stop him but failed. I thought with respect
this was uncontradicted and was reasonably possibly true. In no way
could Mr. Mokuku suggest that the Accused's action had been
unreasonable that far nor that factually it was unreliable except to
say that if true PW 2 should have seen all the occurrences. PW 2
himself has corroborated the Accused's story, which story proved less
likely to be disturbed if the witness admitted (as he did) that at
some stages, due to the terrain, he would not have been able to see
the Accused and the Deceased. It was not suggested by the Crown that
the Accused's story was inherently improbable.
1 could safely accept that the Accused believed that his actions were
lawful. He had to effect arrest of the Deceased on the strength of a
lawful warrant and or reasonable suspicion of having committed a
serious offence. In R v Khaliphile Gogo CRI/T/44/91, 26th August 1992
Kheola J (as he then was) is recorded on page 25 thereof as having
said about the accused:
"Me believed that the deceased had been properly arrested and he
was authorised to stop him from fleeing. The belief was reasonable.
That being so the accused is entitled to be acquitted of culpable
homicide. He (Mr. Penzorn) made reference to the leading South
African decision in S v Blom 1977(3) SA 513 (AD)."
learned judge went on on page 26 to record that:
"In the present case the Accused had a belief based on
reasonable grounds that the deceased was under lawful arrest and he
was escaping the lawful custody or that he was resisting arrest. (My
accused was acquitted and discharged. I however thought an important
jurisprudential question still had to be asked learning from the
interpretation of the said section of South African Law. And of
course based further on influential South African precedents which
approach I alluded on page 15 of this judgment. Although I wondered
as to how for the debate would carry us. This I say in view of the
fact that having accepted that the Accused's story would reasonably
possibly be true, a combination of things included that he ended
acting in self-defence. This was so despite that Accused had placed
himself in the invidious position where he said he then had no choice
but to act in the way he acted.
debate in South Africa is about the greater element of the
constitutional protection of life of an arrestee as his right. Hence
Kriegler J said in Ex Parte Minister of Safety and Security and Three
Others and State v Edward Joseph Walters and Another CCT 28/01
(Minister of Safety and security case) at page 36 
"Our Constitution demands respect for the life, dignity and
physical integrity of every individual. Ordinarily this respect
outweighs the disadvantage to the administration of justice in
allowing a criminal to escape."
section 4(1) (a) of the Constitution of Lesotho. That is how, since
the right to life
paramount, it has to be balanced against the duty of the state to
maintain law and order and in respective cases for a law enforcer to
effect an arrest in similar situation to the present. It should have
been argued in this Court as to how best the right of the arrestee be
protected by interpreting our section 42(1) which is similar to South
African section 49(1). This is a common exercise in South Africa.
"We proceed from the premise that human rights are simply the
basic rights that inhere in each person by reason of the fact that he
or she is a human being. The most basic human right is life itself.
Therefore it is a human rights norm that a person's life cannot be
taken by the State arbitrarily, without due process of law-or at all,
in the view of many."
DEVELOPMENT OF CONSTITUTION AND THE OBSERVANCE OF THE RULE OF LAW IN
THE KINGDOM OF LESOTHO - A memorial lecture in honour of the late Mr.
Justice M.P. Mofokeng, formerly a Judge of the High Court of Lesotho
-- Address delivered on the 10th of October 2002 by the President of
the Court of Appeal of the Kingdom of Lesotho the Honourable J.H.
interpretation of the said section 49(1) the South African Courts
have brought about a pronouncement on how the old test (narrow test)
ought to give way to a new test of reasonableness that is. that:
"proportionality between the seriousness of the relevant offence
and the force used should be expanded to include consideration of
proportionality between the nature and degree of force used and the
threat of the force
posed by the fugitive to the safety and security of the police
officers other individuals and society as a whole."
Govender v Minister of Safety and Security 2001(11) BCLR 1197 (SCA).
See also The Minister of Safety and Security case (supra) per
It was so
argued in Govender's case that the old test as exemplified by Matlou
v Makhubedu 1978(1) SA 946(A) at 957 C-F of what was "reasonably
practicable" was unacceptable in its threshold requirement which
was said to be too low and not complying with the constitutional
standards of reasonableness and justifiability". See Govenders
case page 1203 F-J.
to better illustrate the old test in Matlou v Makhubedu's case
(before 1977 Criminal Procedure Act) it will do no better than quote
the extract from the headnote (the judgment being in Afrikaans) that:
"It must be stressed, however, that each incident must be judged
on its merits in order to determine whether the arrestor had acted
reasonably in terms of this section if he could reasonably have
prevented the suspect from escaping in some way other than seriously
killing or wounding him."
speaking about the requirements of the said section 49(1) which came
after 1976 the
authors of Commentary on the Criminal Procedure Act (du Toit et al)
page 5-27 :
force which was used to overcome the resistance or to prevent the
flight was reasonably necessary in the circumstance. the question at
issue is whether the Accused arrester could reasonably have
restrained the suspect from escaping in another less than drastic
way than by injuring him or injuring him so seriously in the way he
did. (Matlou v Makhubedu 1978(1) SA 946(A) 958. Macu v Du Toit
1983(4) SA 629(A) 635D. other methods need be weighed as alternative
only if they were practicable and reasonably effect to overcome the
resistence or to prevent flight ((Macu v Du Toit (supra) 635 H). A
court should grand against ex post facto speculation as to what
would have been more effective in the circumstances prevailing all
the time of the incident (D Kane v Minister Van Wet En Orde 1992(2)
SALR 211 (W)." (My emphasis)
underlined in the extract above centres around the degree of force
used which will ordinarily be balanced against the seriousness of the
offence hence the said proportionality. This will necessarily take
into account the knowledge on the part of the arrester that the
deceased had committed a serious crime, secondly that the arrester
must have attempted to effect an arrest on the deceased who thereupon
resisted arrest or took flight. And finally if deceased was killed
while escaping, he must have been aware that an attempt was being
made to arrest him.
of Govender further said that while use of force will be accepted to
resistence such force is reasonable if there were objectively
grounds for believing that:
the suspect posed on immediate threat of serious bodily harm to him
or to her or a threat on members of the public or
the suspect has committed a crime involving the infliction or threat
of serious bodily harm." See page 1206.
case it was decided that the use of a firearm was excluded in the
circumstances in that the "threat" or danger was not
commensurate or such as to attract that kind of a weapon because the
new test introduced a "consideration of propotionality between
the nature and the degree of force used and the threat posed to the
arrester by the fleeing suspect."
Minister of Safety and Security case, at page 32, while approving of
the principles enunciated in Governer's case, stresses what perhaps
ought to be stressed being the impression that law enforcers may have
had a licence to execute suspects extrajudicially by saying:
"One needs to add to a weighty consideration before the live of
suspects can be risked by using a firearm or some other form of
potentially deadly force merely to prevent escape."
learned judges develops the theme further by introducing the aspect
of seriousness of offence or "the scheduling of the offences"
on the same page at  by
"Subscction(2) finds this additional consideration in the
seriousness of the offence for which the fugitive is to be arrested.
The legislature clearly wished to limit the licence to kill to
serious cases. The spectre of a child being shot died for snatching a
mealie meal is, after all, start. The mechanism chosen in subsection
(2) to maintain reasonable propotionality with the use of deadly
force, was to draw a distinction line between lesser and more serious
offences and to permit the use of deadly force for arrest of fugitive
suspected of having committed serious crimes in more serious
categories. This was done by introducing the first schedule and
providing that lethal force may be legally warranted in arresting
fugitives suspected of having committed one or other of the
learned judge then summarised the main points before dealing with
other and more involved issues of the case and then said at page 45
order to make perfectly clear what the law regarding this topic now
is, I tabulate the main points:
purpose of arrest is to bring before court for trial persons
suspected of having committed offences.
is not the only means of achieving this purpose, nor always the
may never be used to punish a suspect.
arrest is called for, force may be used only where it is necessary
in order to carry out the arrest.
force is necessary, only the least degree of force reasonably
necessary to carry out the arrest may be used.
deciding what degree of force is both reasonable and necessary, all
the circumstances must be taken into account, including the threat
of violence the suspect poses to the arrester or others, and the
nature and circumstances of the offence the suspect is suspected of
having committed; the force being proportional in all these
a suspect solely in order to carry out an arrest is permitted in
very limited circumstances only.
such shooting is not permitted unless the suspect poses a threat of
violence to the arrester or others or is suspected on reasonable
grounds of having committed a crime involving the infliction or
threatened infliction of serious bodily harm and there are no other
reasonable means of carrying out the arrest, whether at that time or
limitations in no way detract from the rights of an arrester
attempting to carry out an arrest to kill a suspect in self-defence
or in defence of any other person. (My emphasis)
concluded the last two points ought to be emphasized to illustrate
what I considered to have been the greater issues of interest in this
case in the context of the South African debate.
be clear by now that I would accept that the Accused's story of what
transpired might reasonably possibly be true. See R v Difford 1946 AD
1023 at 1027. The Accused then deserves the benefit of doubt. And
furthermore with the element of self-defence which his story
contained it added more to his being entitled to shoot and kill in
the context of a justifiable homicide in terms of section 42(1) of
Accused is accordingly acquitted and discharged. My assessors agreed.
African Law (AfricanLII)
Ghana Law (GhaLII)
Laws of South Africa (Legislation)
Lesotho Law (LesLII)
Liberian Law (LiberLII)
Malawian Law (MalawiLII)
Namibian Law (NamibLII)
Nigerian Law (NigeriaLII)
Sierra Leone Law (SierraLII)
South African Law (SAFLII)
Seychelles Law (SeyLII)
Swaziland Law (SwaziLII)
Tanzania Law (TanzLII)
Ugandan Law (ULII)
Zambian Law (ZamLII)
Zimbabwean Law (ZimLII)
Commonwealth Countries' Law
LII of India
United States Law