Human Rights Watch documented two cases involving Guéré women who said that, since inheriting land, the renter had refused to continue paying rent paid when the woman’s father or husband, respectively, was alive.105 One of the cases originated with the crisis, during which the 52-year-old woman’s husband died: My husband [separately] installed three Baoulés [years ago], who planted cocoa. [The cocoa] has been in production for several years. Two of them were just workers, but one had a rent agreement with my husband…. My husband died in February 2011, and I fled in March when the war arrived. I was [displaced] at the Catholic mission [in Duékoué]. Since coming back to the village, the Baoulé has not paid rent. In 2012, I received nothing. So far in 2013, nothing…. I’ve tried to call him to the village to resolve this, but he doesn’t come…. Nobody responds to me. For me as a woman, it’s not easy to go into the bush after them.106 The claims related to rent can be difficult to assess. Most Guérés who complained about non-natives’ refusal after the crisis to continue honoring rent agreements said the contract had been oral. Others said there had been a written agreement on informal papers, but those had been destroyed along with people’s homes during the crisis. In such cases, authorities would likely need to establish that both parties had accepted and carried out the division every year—or with every cocoa harvest—prior to the crisis, demonstrating that such an agreement existed. In cases where there was an agreement to pay annual or seasonal rent, the failure to do so as a result of a person’s displacement would, like an illegal sale, violate the right to property under the African Charter. Illegal Extension of Acquired Parcels In some villages, Human Rights Watch documented cases where non-natives who previously acquired some of an owner’s land appear to have illegally extended their holdings while the owner was displaced. Assessing these claims’ credibility is again 105 Human Rights Watch interview with alleged victim of breach of rent agreement, Fengolo, February 10, 2013; and with alleged victim of breach of rent agreement, Oulaïtaïbly, June 6, 2013. 106 Human Rights Watch interview with alleged victim of breach of rent agreement, Fengolo, February 10, 2013. 39 HUMAN RIGHTS WATCH | OCTOBER 2013