border villages south of Bloléquin on March 13 and 23 and destroyed dozens of homes. Land sale documents seen by Human Rights Watch indicate that attackers appear to have targeted some victims for their perceived role in allegedly illegal land transactions. There have also been several inter-communal clashes in 2013—with Guérés from two villages fighting each other over allegations of fraudulent land sales. Fiery rhetoric is recurrent in many villages, and tensions threaten to erupt into additional clashes. The dispossession of Guéré land in the aftermath of the post-election crisis must be seen in the context of what happened in western Côte d’Ivoire after the 2002-2003 armed conflict. Then, the non-native population was forced to flee as they were targeted by proGbagbo forces for serious crimes; many were unable to return for four years. Some Guéré landowners imposed extortionate conditions on the non-natives’ return, taking back parts of previously ceded land or demanding money to recover a person’s own property. Other Guérés illegally sold or re-sold land during non-natives’ displacement. Burkinabé leaders in western Côte d’Ivoire described some of the recent seizures as “recovering” this land. That likely has occurred, though illegal sales and seizures have undoubtedly gone well beyond re-acquisitions. The tit-for-tat nature of land dispossession in western Côte d’Ivoire is one of the many forms of vigilante justice practiced there over the last decade. It will likely continue until Ivorian authorities are able to establish confidence in the rule of law as the way to resolve disputes, including over land. Under the Pinheiro Principles, states “should establish and support” through “adequate financial, human and other resources … equitable, timely, independent, transparent and non-discriminatory … mechanisms to assess and enforce … land and property restitution claims.” To date, the Ivorian government has largely failed to meet that responsibility, although the opening of a new tribunal in Guiglo in June 2013 should increase the access to the justice system for people living in far western Côte d’Ivoire. Customary and administrative mechanisms dealing with land conflicts are often overwhelmed with claims in western Côte d’Ivoire, particularly related to the post-election crisis. In western Côte d’Ivoire, village chiefs and sub-prefects, the main customary and administrative officials responsible for resolving land conflicts, collectively have thousands of cases before them. Yet they have received remarkably little financial support from the national government—often either crippling their ability to investigate and resolve 5 HUMAN RIGHTS WATCH | OCTOBER 2013