system, a birth certificate is in principle required to obtain any official papers of this type – which very few Bakassi residents hold; a jugement supplétif from a tribunal would be required to obtain late registration of birth, a time-consuming and potentially costly process.224 While the Cameroonian government gave assurances to the ICJ that the Bakassi residents would be made as welcome as other Nigerians in Cameroon, the situation of those who are living where they have always lived is significantly different from those who have moved to Cameroon for other purposes.225 Without identity documents, Bakassi residents are vulnerable to extortion at police checkpoints in Cameroon. Meanwhile, several thousands of Bakassi residents have relocated to the other side of the Nigerian border. The Cross Rivers government has purported to carve out a new local government area for the Bakassi displaced – though it has no constitutional authority to do so – and is granting or facilitating some humanitarian assistance.226 At the federal level, no agency has taken charge of resolving the situation of the Bakassi displaced; and in particular there has been no effort to document them, and thus provide them with proof of Nigerian citizenship. As a consequence, they have also been denied the right to vote in various elections, since the locations where they were registered no longer exist; there is ongoing litigation by the Independent National Electoral Commission on this point.227 In February 2014, Nigerian Attorney General of the Federation and Minister of Justice Mohammed Adoke, speaking at the opening of the 32nd Session of the Mixed Commission, stated that those affected by the judgment who wished to be Nigerian should simply “apply for Nigerian citizenship” showing a rather alarming disregard for the difficulty of doing so under the Nigerian constitution, but also implying that they need to naturalise, rather than obtain recognition of ongoing nationality from birth (see further sections 2.6.3 and 3.3).228 Lobbying continues in Nigeria for the government to retake control of the peninsula. 4.6.2. Other border disputes In a judgment from 1986 adjudicating a frontier dispute between Burkina Faso and Mali, the court noted the difficulty of “ascertain[ing] where the frontier lay in 1932 in a region of Africa little known at the time and largely inhabited by nomads, in which transport and communications were very sketchy.”229 Affirming the principle of uti possedetis (by which territory remains with the possessor), the court noted that: “At first sight this principle conflicts outright with another one, the right of peoples to self-determination. In fact, however, the maintenance of the territorial status quo in Africa is often seen as the wisest course, to preserve what has been achieved by peoples who have struggled for their independence, and to avoid a disruption which would deprive the continent of the gains achieved by much sacrifice.”230 The court emphasised the decision of African states to respect colonial 224 Fongot Kini-Yen Kinni, Bakassi: Or the Politics of Exclusion and Occupation? Langaa Research and Publishing Common Initiative Group, Cameroon / African Books Collective, 2013. 225 Cameroon v. Nigeria, ICJ Judgement of 10 October 2002, paragraph 317. 226 The National Commission for Refugees, Migrants and Internally Displaced Persons was reported by the Cross River State government to have distributed relief supplies to more than 1,500 households in two local government areas in the state. See “Bakassi, Akpabuyo Refugees Get Relief from Refugees Commission” Cross Rivers State government, 29 July 2013. 227 Jude Okwe, “INEC - Bakassi May Not Participate in 2015 Elections”, This Day, 4 April 2014; interview with Chidi Anselm Odinkalu, chair Nigerian National Human Rights Commission, July 2014.. 228 Dele Ogbodo, “Greentree Agreement: FG Advises Bakassi Indigenes to Apply for Nigerian Citizenship”, This Day, 3 February 2014 229 Frontier Dispute (Burkina Faso/Mali), ICJ Judgment of 22 December 1986, paragraph 64. 230 Ibid., paragraph 25. 69