on the return that deprived these populations of the ability to recuperate their entire property.118 This situation, a mirror image of the events following the post-election crisis, violated immigrants’ and non-native Ivorians’ rights under the African Charter and as set out in the Kampala Convention and the Pinheiro Principles. When Guérés were forced to flee during the post-election crisis, some immigrants and nonnative Ivorians saw it as an opportunity to reclaim their original plantations. A Burkinabé leader in Bloléquin told Human Rights Watch: “It wasn’t until the post-election crisis that [all Burkinabés] were able to get their entire plantations back…. There was no longer anyone to oppose them, so they were able to recuperate the plantations they’d lost.”119 A humanitarian official in western Côte d’Ivoire who works on land issues likewise said: “When there was a reversal in who had power, the Burkinabés recuperated their old parcels.”120 Yet the humanitarian official said that some appeared to have gone further, passing the pre-2002 limits of their land.121 Customary, administrative, and judicial authorities dealing with cases of illegal extensions should consider and nullify any illegal seizures by Guérés while immigrants and non-native Ivorians were displaced by the 2002-2003 conflict. However, where non-natives have now passed these limits—or, as in several cases described above, even extended into land owned by another Guéré, generally a neighbor—the seizures violate rights under human rights law and the rightful owner should be accorded restitution. Above all, the tit-for-tat illegal land seizures demonstrate the inadequacy of existing mechanisms in determining rightful owners as well as people’s lack of confidence in the capacity of law enforcement, local authorities, and the judicial system to investigate and resolve conflicts. Over the last 13 years, people in western Côte d’Ivoire have repeatedly resorted to vigilante justice in conflicts over land, power, and politics. The cycle will continue to repeat until the Ivorian government is able to establish trust in the rule of law and to end the impunity for those who engage in fraud to illegally sell land. 118 Ibid. See also Interpeace, “Dynamiques et Capacités de Gestion des Conflits à l’Ouest de la Côte d’Ivoire,” January 2013, p. 33; and IDMC and NRC, “Whose land is this?” October 2009, p. 29. 119 Human Rights Watch interview with Burkinabé community leader, Bloléquin, June 8, 2013. 120 Human Rights Watch interview with humanitarian official, western Côte d’Ivoire, February 12, 2013. 121 Ibid. 43 HUMAN RIGHTS WATCH | OCTOBER 2013