Article 8 of the African Charter on Human and People’s Rights (ACHPR) guarantees the “free practice of religion,”140 which the African Commission has said includes animist “spiritual beliefs and ceremonial practices.”141 In a case involving a community in Kenya, the Commission ruled that the eviction from ancestral land including “sacred grounds essential to the practice of their religion” was a violation of their article 8 rights.142 The forests and waters held sacred by Guéré communities and used for religious or ceremonial practices would arguably likewise be protected by the African Charter. Unlike in the Kenya case, the Ivorian government has not been involved in the de facto evictions related to the post-election crisis. However, the Ivorian government still has obligations to protect—both in law and in practice—sacred land from being destroyed or occupied by non-state actors. When sacred land has been seized, violating the local community’s rights, the Ivorian government should take steps to return the land to that community. Impact on Food Security, Livelihoods Land dispossession has serious consequences on the livelihoods and food security of those who have lost their land. Problems are particularly acute in western Côte d’Ivoire, where the conflict displaced hundreds of thousands of people and involved the burning or destruction of thousands of homes. When people returned, they often had few possessions left and had been unable to profit from cash crops or stockpile food crops while displaced. Many expressed grave concern about sustained food insecurity should they continue to be unable to access land now occupied illegally. A Guéré from Goya, just outside Bloléquin, said that three hectares of his land had been illegally sold while he was a refugee in Liberia, between March and May 2011. He had only been able to file a complaint against “X,” saying that the Burkinabés had refused to tell him who sold them the land. He described the difficulties caused by being unable to access his land for at least 19 months: [The occupation of my land] has aggravated my situation from the crisis. My house, my campement, everything was burned and destroyed during the 140 ACHPR, art. 8. 141 African Commission on Human and People’s Rights, Centre for Minority Rights Development (Kenya) and Minority Rights Group International on behalf of Endorois Welfare Council v Kenya, Communication 276/2003, adopted by the African Union on February 4, 2010, para. 168 (“Endorois Welfare Council v Kenya”). 142 Ibid., para. 173. 49 HUMAN RIGHTS WATCH | OCTOBER 2013