OF THE FEDERAL DEMOCRATIC REPUBLIC OF ETHIOPIA Oth Year No. 65 ADDIS ABABA - 84 June , 2003 CONTENTS Proclamation No. 345/2003 Public Servants ' Pensions Proclamtion PROCLAMATION No. 345/2003 PUBLIC SERVANTS ' PENSIONS PROCLAMATION WHEREAS , it is found necessary to strengthen , to the extent the pension legislations ; NOW , THEREFORE , in accordance with Article 55 ( 1 ) of the Constitution of the Federal Democratic Republic of Ethiopia , it is hereby proclaimed as follows ; PART ONE General This Proclamation may be cited as the “ Public Servants ' Pensions Proclamation No.345 / 2003 . ” 2. Definitions In this Proclamation , unless the context otherwise requires : 1 ) " Public Servant ” means a person permanently em ployed in any public office , and includes a govern ment appointee , member of the Defense Force and the Police ; 2 ) “ Public Office ” means an office wholly or partly run by government budget , and includes public enter Unit Price The African Law Archive 36. Orphan's Pension 1 ) The amount of pension payable to each surviving child shall be twenty per cent ( 20 % ) of the pension to which the deceased was or would have been entitled . 2 ) If both parents are dead , the amount of pension payable to each surviving child in accordance with Sub - Article ( 1 ) of this Article shall be thirty per cent 3 ) If both parents of an orphan who were or would have been entitled to a pension are dead , he shall receive twenty per cent ( 20 % ) of each of their pension . Provided , however , that the amount of pension payable in accordance with this Sub - Article shall not be less than the amount payable accordance with Sub - Article ( 2 ) of this Article . 37. Parent's Pension The amount of pension payable to each parent shall be fifteen per cent ( 15 % ) of the pension to which the deceased was or would have been entitled . If there are no other survivors the amount shall be twenty percent ( 20 % ) 38. Survivors ' Gratuity The amount of gratuity payable to any survivor shall he the amount of gratuity to which the deceased would have been entitled and shall he calculated in accordance with the percentage specified in Article 35 ( 1 ) or 36 of this Proclamation . 1 ) If the total benefits payable to survivors , in accor dance with Article 35 through 38 of this Proclamation is in excess of hundred percent ( 100 % ) of the benefit to which the deceased was or would have been entitled , each survivor's share shall be proportionately reduced until the total comes down to hundred percent ( 100 % ) . Upon reduction in the number of survivors suh sequent to adjustment under Sub - Article ( 1 ) of this Article , further adjustment of the amount of benefits shall be made . PART EIGHT General Provisions Relating Benefits On the basis of studies submitted to it by the Authority , the Council of Ministers may adjust pension benefit every five years . 41. Mode and Period of Payment of Pension Pension shall be effected monthly . 2 ) Payment of retirement pension shall begin as of the month following that in which the public servant retires . 3 ) Payment of invalidity pension shall begin as of the month following that in which the invalidity of the public servant ascertains . 4 ) Payment of incapacity pension shall begin as of the month following that in which the permanent total incapacity sustained by the public servant ascertains . 5 ) Payment of survivors ' pension shall begin as of the month following that in which the beneficiary dies . The African Law Archive – No. 65 8 June , 2003– Page 2219 42. Mode and Period of Payment of Gratuity 1 ) Any gratuity is effected in lump sum at once . 2 ) Retirement or invalidity gratuity shall be payable beginning with the first day of the month following that in which the public servant separates from the service . 3 ) Incapacity gratuity shall be payable beginning with the first day of the month following that in which the injury sustained by the public servant ascertains . 43. Period of Limitation 1 ) Any claim for payment of arrears of pension shall be barred by limitation after one ( 1 ) year . 2 ) Any claim for payment of gratuity shall be barred by limitation after two ( 2 ) years . 3 ) A claim for reimbursement of pension contribution shall be barred by limitation two years after the date in which the public servant attains retirement age or 4 ) The period of limitation shall begin to run from the day following that in which the right may be exercised . 5 ) The period of limitation shall not include the following : ( a ) period lapsed due to a court process started to establish right , ( b ) period lapsed due to non fulfillment by the employer its obligation to submit evidentiary documents on time , ( c ) periods necessary for the decision of benefit entitlement by the Authority . The right to receive benefits shall not be pledged or can not be transferred by inheritance or any other means . 45. Attachment of Benefits Benefits payable in accordance with this Proclamation shall not be attached for any debts unless ordered by a court in respect of : 1 ) Public fines , public fees or taxes ; or 2 ) Fulfillment of the obligation to supply maintenance in accordance with relevant Civil Code provisions . PART NINE Miscellaneour Provisions 46. Relationship Between Entitlements 1 ) If a public servant who receives retirement pension re - enters the public service and receives salary , the pension shall be discontinued ; 2 ) If a pensioner is re - employed permanently in a public office , the service shall be added and counted with previous service for the purpose of benefit entitlement . However , if the new benefit is less than the former benefit the pensioner shall have the right to get the previous benefit ; 3 ) If a beneficiary is entitled to more than one benefit , the amount of benefit to be paid shall be decided by the authority ; 4 ) Without prejudice to Article 10 ( 2 ) of this Proclamation , a retired employee of nationalized enterprise who is receiving monthly benefit on the date of such nationalization shall continue to get the amount of pension benefit adjusted to the ap propriate provision of this Proclamation . The African Law Archive 47. Obligation of Employers 1 ) Any employer shall collect , compile and submit to the Authority evidentiary documents relating to employees which are necessary for the implemen tation of this Proclamation in accordance with the form and within the time decided by the Authority ; 2 ) for the purpose of implementing this Proclamation , any government office mass or private organization or individual shall furnish information or written evidence or appear and testify or give his opinion when so requested by the Authority . 48. Decision of the Authority 1 ) The fulfillment of conditions for entitlement to any kind of benefit payable in accordance with this Proclamation and the amount of the benefit shall be decided by the Authority ; 2 ) The decision of the Authority regarding those specified in Sub - Article ( 1 ) of this Article shall be based on its own record , evidentiary document submitted to it in accordance with Article 47 of this Proclamation and , as the case may be , on additional evidences produced by the beneficiary ; 3 ) When difference occurs between the records of the Authority and documents provided by other organs , the evidentiary document to be accepted shall be decided by the Authority . 1 ) The Authority may review its previous decision upon request by an aggrieved beneficiary or on its own initiative ; 2 ) Where upon review the Authority finds that there is reasonable ground for cancellation or deduction of benefits , it may suspend payment to the extent the benefit is to be cancelled or deducted ; 3 ) Notwithstanding the provisions of Article 45 of this Proclamation , upon decision of deduction of any benefit payment contrary to this Proclamation the Authority shall deduct the amount paid thereof illegally from the benefit of the pensioner and transfer it to the funds . 50. Appeal Any public servant or survivor who is aggrieved by the decision of the Authority made pursuant to Article 48 or 49 of this Proclamation , shall have a right to lodge an appeal to the Social Security Appeal Tribunal established in accordance with Article 11 of the Social Security Authority Establishment Proclamation No. 38/1996 . 51. Tax Exemption Not tax shall be payable on benefits received , pension contribution collected and profit from investment of ension fund in accordance with this Proclamation . The African Law Archive 52. Transitory Provisions 1 ) Previous laws and directives shall remain applicable to legal situations created before the coming into force of this Proclamation ; 2 ) Notwithstanding the provisions of Sub - Article ( 1 ) of this Article , a public servant lawfully retained in service beyond retirement age before the coming into force of this Proclamation shall have a right to remain in service until he attains the retirement age set forth in this Proclamation ; 3 / Until the Authority issues the schedule determining the degree of incapacity specified in Article 24 the practices followed by the medical boards shall remain applicable . 53. Power to Issue Regulations and Directives 1 ) The Council of Ministers may issue regulations necessary the implementation of this Proclamation ; 2 ) The Authority may issue directives necessary for the implementation of this Proclamation and regulations issued pursuant to Sub - Article ( 1 ) of this Article . 54. Penalty Who ever violates the provisions of this Proclamation or regulations and directives issued pursuant to this Proclamation shall be punished in accordance with the appropriate Penal Law provisions . 55. Repealed and Inapplicable Laws 1 ) The following are hereby repealed : ( a ) Public Servants ' Pensions Proclamation No. 209/1963 ( as amended ) ; ( b ) Public Servants ' Pension Contribution Proclamation No. 199/1963 ( as amended ) ; ( C ) Employees of Government Owned Under takings Pension Proclamation No. 49/1975 ; 2 ) No law and directives shall , in so far as it is inconsist with this Proclamation , have force and effect in respect of matters provided for in this Proclamation . 56. Effective Date This Proclamation shall enter into force as of gil : day of June , 2003 . Done at Addis Ababa , this goh day of June , 2003 . PRESIDENT OF THE FEDERAL DEMOCRATIC REPUBLIC OF ETHIOPIA The African Law Archive 3 ) “ Public Organ ” means public offices , and includes Councils established at a Federal Government and Regional States levels and City Administration ; 4 ) “ Government ” includes the Federal Democratic Republic of Ethiopia and the Regional States ; 5 ) “ Member of the Defense Force ” means a person permanently employed in Defense Force to render military service ; 6 ) " Member of the Police ” means a person permanently employed and render service under the Federal or Regional States Police establishement legislations ; 7 ) “ Civil Service ” means service rendered by public servants other than members of the Defense Forces and the police ; 8 ) “ Military Service ” means a service rendered by members of the Defense Force ; 9 ) “ Police Service ” means a service rendered by mem bers of the police ; 10 ) “ Enterprise ” includes public enterprises and enter prises in which the government's capital share is not less than fifty percent ( 50 % ) ; 11 ) " Employer ” means a public office or public organ which pays salaries to public servants , or any organ which pay salaries for persons whose period of service is counted under this Proclamation ; 12 ) “ Salary means monthly salary received by a public servant , for services rendered during regular working hours , without the deduction of any amounts in respect of income tax or any other matter ; 13 ) “ Benefit ” means retirement pension , invalidity pension , incapacity pension or survivors ' pension and includes gratuity and the refundable pension contribution , 14 ) “ Beneficiary ” means a public servant or his survivor who receives benefits or fulfils the con ditions for receiving benefits in accordance with this Proclamation ; 15 ) “ Survivor ” includes persons mentioned under Ar ticle 34 ( 3 ) thereof , 16 ) “ Authority ” means Social Security Authority ; 17 / “ Pensions Funds ” means public servant's Pension Funds established for the purpose of Pension Funds contributions being collected and effecting benefit payments provided by this Proclamation . 3. Scope of Application Without prejudice to the appropriate provision of the Proclamation 270/2002 that provides pension coverage to foreign nationals of Ethiopian origin , any international and bilateral agreements to which the country is a party , this Proclamation shall be applicable to public servants of The African Law Archive - No. 65 8 June , 2003– Page 221 1 PART TWO PENSION FUNDS AND CONTRIBUTIONS 4. Pension Funds The following Public Servants ' Pension Funds are hereby established by this proclamation . 1 ) Civil Service Fund . 2 ) Military and Police Service Fund . Civil Service Fund Contributions The amount of the contribution payable to the Civil Service Fund , based on the salary of the Public Servant shall be : 1 ) by the employer six percent ( 6 % ) , 2 ) By the public servant four percent ( 4 % ) . 6. Military and Police Fund Service Contributions The amount of the contribution payable to the Military and Police Service Fund based on the Salary of the member of the Defense Force and the Police shall be : 1 ) by the employer sixteen percent ( 16 % ) , 2 ) by the public servant four percent ( 4 % ) . 7. Payment of Contributions 1 ) Each Employer shall deduct the contribution due upon each public servant's salary and shall pay the amount , together with the contribution due from the office as an employer , into the pension fund mon thly ; 2 ) Where the contribution due upon a public servant's salary is not deducted , the concerned employer shall be responsible for payment of the same ; 3 ) Any employer who fails to pay the contribution to under Sub Article ( 1 ) of this Article , until the last day of each subsequent month , shall pay monthly an amount of 2 % on the un paid arrear contributions . 4 ) The payment of contribution to Pension Funds has priority over any payments of debts . 8. Administration of the Pension Funds The Authority shall administer the Funds referred to under Article 4 of this Proclamation . Utilization of the Pension Funds 1 ) Without prejudice to Article 12 ( 1 ) of the Socail Security Authority establishement Proclamation No. 38/1996 , the Pension Funds shall be utilized only for effecting benefit payments stipulated in this Proclamation and investment purpose . 2 ) The Pension Funds shall not be attached in respect of debt . PART THREE Period of Service and Retirement Age 10. Commencement of Period of Service 1 ) The period of service of a public servant begins with the date of his appointment or assignment as a public servant . 2 ) The period of service of a public servant working in an entrprise transferred to the government ownership shall begin to count as of the date of such transfer . However , the service of employees of such enter prise which has a pension scheme or a provident fund that can balance due amount of pension contribution shall be counted , provided that the accumulated fund is wholly transferred to the Public Servants ’ Pension Funds . The African Law Archive 11. Calculation of Period of Service 1 ) Period of service of a public servant shall he calculated in complete years , months and days ; 2 ) Periods of service rendered by any public servant in different public offices shall be counted up ; 3 ) Period of service of a member of the Defence Force or a Police temporary rendered in a duty other than his regular service upon a government order shall be treated as military or police service : For any public servant the following shall also be counted as period of service ; the period of service beyond retirement age lawfully retained ; ( b ) the period of service spent after reinstatement upon a government decision subsequent to retirement due to age ; ( c ) the period of service which was interrupted without interruption of payment of salary ; ( d ) the period of service spent in any public organ by election with regular salary as People's Representative on full time basis ; ( e ) the period of service rendered temporary without interruption in a government office if subsequently employed permanently in the same office ; ( f ) The period of Service rendered in a privatized public enterprise having been transferred along with the enterprise ; ( g ) The period of service spent upon a govern ment order in international organizations or enterprises where the government capital share is less than fifty per cent ( 50 % ) . 5 ) For any public servant the following shall not be counted as period of service ; ( a ) unless lawfully retained , the service he renders as of the first day of the month following that in which he attains retirement age ; ( b ) without prejudice to any international agr eement to which Ethiopia is a party , service ren dered in any public office by a public servant of Ethiopian nationality by naturalization , prior to such naturalization . 6 ) Period of service referred to under Sub - Article 4 ( d ) to ( g ) of this Article shall be counted as period of service only where the public servant pays the contribution due from him and the employer on his own or made the employer pay the same based on the salary paid to him prior to the interruption of his service . 7 ) Where a public servant who has received gratuity or to whom reimbursement of pension contribution was made pursant to this Proclamation is employed or assigned as a public servant , his former service shall be counted along with the new , provided that the gratuity or the reimbursed contribution is paid back with bank interest . 8 ) On the basis of studies submitted to it by the Authority , the Council of Ministers may decide that period of service spent on hazardous jobs or on jobs involving risk to health and life be counted , as the case may be , upton twice the actual period of service . The African Law Archive 12. Retirement Age 1 ) The retirement age of public servants shall be as follows : ( a ) for members of Defence Force at the age which shall be determined by the appropriate provisions of Defence Force establishment Proclamation . ( b ) for the members of the Police at the age which shall be determined by the appropriate provisions of Police establishment leg islations . ( c ) for all other public servants sixty ( 60 ) years . 2 ) On the basis of studies submitted to it by the Authority the Council of Minister may determine higher retirement age for profficianal fields which may need special consideration than the provided under Sub - Article ( 1 ) of this Article .. 3 ) On the basis of studies submitted to Authority , the Council of Ministers may decide earlier retirement age than the provided under Sub Article ( 1 ) of this Article in the case of public servants working on hazardous jobs involving risk to health and life . by the PART FOUR Retirement Pension and Grtuity 13. Retirement Pension 1 ) A public servant who has completed at least ten ( 10 ) years of service , and retires upon attaining retirement age , shall receive retirement pension for A public servant who has completed at least twenty ( 20 ) years of service and separates from the serivce by voluntary resignation or for any other causes other than those provided in this Proclamation shall receive retirement pension for life upon attaining retirement age . A public servant other than member of the Defense Force who resigns after completing at least twenty five ( 25 ) years of service shall receive retirement pension for life beginning with five years prior to retirement age . 4 ) A member of Defence Force who resigns after completing at least twenty five ( 25 ) years of service shall receive retirement pension for life beginning with three ( 3 ) years prior to retirement age . 5 ) Where it is ascertained that a public servant who has separated from service in accordance with Sub Article ( 2 ) through ( 4 ) of this . Article becomes incapable of fulfilling the medical conditions of service due to failure in health prior to attaining retirement age , he shall receive invalidity pension for life as of the month following such ascertain ment ; in case he dies , his surviours shall be paid benefits as of the month following such death . 14. Amount of Retirement Pension The retirement pension due to any civil servant shall amount to thirty percent ( 30 % ) of the average salary for the last three years preceding retirement , increased for each year of service beyond ten ( 10 ) years ; 1 ) For a public servant other than member of the Defense Force or Police by one point one two five 2 ) For a member of the Defense Force or Police by one point five per cent ( 1.5 % ) . However ; the retirement pension to be paid pursuant to Sub - Article ( 1 ) and ( 2 ) of this Article shall not exceed seventy percent ( 70 % ) . The African Law Archive 15. Retirement Gratuity A public servant who has not completed ten ( 10 ) years of service and retires on attaining retirement age shall receive gratuity . 16. Amount of Gratuity The gratuity payable in accordance with Articel 15 of this Proclamation shall be ; 1 ) For a public servant other than member of the Defense Force or Police the salary of the month preceding retirement multiplied by the number of years of service ; 2 ) For a member of the Defence Force , or Police the salary of one and one - half month preceding retirement multiplied by the number of years of service . PART FIVE Invalidity Pension and Gratuity 17. Invalidity Pension A public servant who has completed at least ten ( 10 ) years of service and is retired because he dose not fulfill the medical condition of service shall receive invalidity pension for life . 2 ) If a beneficiary who is receiving invalidity pension engages in any gainful activity and begins getting salary the pension shall be discontinued . 18. Amount of Invalidity Pension The invalidity pension payable by this Proclamation shall be calculated as provided under Article 14 thereof , 19. Invalidity Gratuity A public servant who has not completed ten ( 10 ) years of service and retires because he does not fulfil the medical condition shall receive invalidity gratuity . The gratuity payable in accordance with Article 19 of this Proclamation shall be calculated as provided under Article 16 thereof . 21. Reimbursement of Contribution A public servant : 1 ) Who separates from work due to resignation after completing ten ( 10 ) years , but prior to completing twenty ( 20 ) years of service , or 2 ) Who separates from work for any other cause other than specified by this Proclamation prior to twenty ( 20 ) years of service . Shall be paid an amaunt equal to the total four percent ( 4 % ) contribution there fore mode by him . 3 ) Who separates from work due to resignation prior to completing ten ( 10 ) years service shall be entitled to no benefit . PART SIX Employment Injury and the Payment of benefit 22. Definitions 1 ) “ Employment Injury ” means employment accident and occupational disease ; The African Law Archive 2 ) “ Employment Accident ” means any organic injury or functional disorder suddenly sustained by a public servant during or in connection with the performance of his work , and shall include the following : ( a ) injury sustained by a public servant outside of . his regular work , or outside of his regular working place or hours , while carrying out orders by a competent authority ; ( b ) injury sustained by a public servant during or outside of working hours while attempting to save his work place from destruction of imminent danger , though without order by a competnet authority ; ( c ) injury sustained by a public servant while he is proceeding to or from his place of work in a transport service vehicle provided by the office which is available for the common use of its employees or in a vehicle hired and expressly destined by the office for the same purpose . ( d ) any injury sustained by a public servant before or after his work or during any interruption of work , if he is present in the work place or the premises of the undertaking by reason of his duties in connection with this work , ( e ) any injury sustained by a public servant as a result of an action of the employer or a thrid person during the performance of his work . “ Occupational Disease ” means any pathological condition of a public servant which arises , as a consequence of the kind of work he performs or because of the surrounding in which he works , being exposed to the agent that cause the disease for a certain priod prior to the date in which the disease became evident ; provided , however , that it does not include endemic or epidemic disease which are prevalent and contracted in the area where the work is done . 4 ) “ Regular Work ” means a work performed by a public servant pursuant to his responsibilities or contract of employment . 5 ) “ Regular Place of Work ” means a place where a public servant regularly performs his duties . 23. Self Inflicted Injury The provisions of Article 22 of this Proclamation shall apply only where the public servant has not inflicted the injury upon himeslf intentionally ; any injury resulting from the following acts in particular shall be deemed to be intentionally caused by the public servant . 1 ) non - obedience of expressed safety instruction of non - observance of the provisions of accident preventive rules specially issued by the employer , 2 ) reporting to work in a state of intoxication that prevents him from properly regulating his conduct or understanding The African Law Archive No. 65 8 June , 2003 -- Page 2216 24. Occupational Disease and Extent of Incapacity Schedule The Authority , in consultation with the appropriate organ , shall by directives issue a schedule which list , 1 ) The degree of incapacity , 2 ) Regarding each occupational disease indicating ; ( a ) the symptoms , ( b ) the kind of work or surrounding that gives ( c ) the minimum of exposure & the agent causing the diesease . The schedule shall be revised wherever it may be deemed necessary . 25. Presumption 1 ) Where a disease listed in the schedule in connection with a work place or with a kind of work is contracted by a public servant in a corresponding situation , it shall be presumed an occupational disease . 2 ) Where a public servant who had recovered from an occupational disease is reinfected due to continued placement in the occupation corresponding to the disease listed in the schedule , he shall be presumed to have contracted another occupational disease . 3 ) Notwithstanding the provisions of Article 22 ( 3 ) of this Proclamation where a public servant engaged in the eradication of endemic or epidemic disease contracts same , it shall be presumed an occupational disease . 26. Admissibility of Proof Proof may be permitted to the effect that a disease not listed in the schedule issued under Article 24 here in above could be of occupational origin , and that diseases listed in the schedule are manifested in a different symptom than that indicated therein . 27. Notification of Accident Where a public servant other than member of the Defense Force sustains occupational injury the employer shall notify in writing the same with in thirty ( 30 ) days of the occurrence of such accident to the Authority . 28. Assessment of Employment Injury 1 ) The extent of employment injury sustained by a public servant shall be assessed by authorized medical board in accordance with the schedule to be issued pursuant to Article 24 of this Proclamaiton . 2 ) The Medical Board shall assess the extent of employment injury based on the directives to be issued by the Authority . 3 ) When it deems necessary , the Authority can refer the assessment to another medical board for further evaluation . 29. Incapacity Benefit Incapacity pension for life or incapacity gratuity shall be paid as the case may be , for injury sustained from employment . The African Law Archive No. 65 8 June , 2003-- Page 2217 30. Incapacity Pension 1 ) A public servant who sustains employment injury of not less than ten percent ( 10 % ) and separates from work due to absolute incapacitation shall receive an incapacity pesnion for life . 2 ) If a beneficiary who is receiving incapacity pension engages any gainful activity and hegins getting salary , the pension shall be discontinued . 1 ) In accordance with this Proclamation a public servant who sustains employment injury shall receive an incapacity pension for life amounting to forty five percent ( 45 % ) of his basic monthly salary which he was receiving during the month prior to the occurence of the injury . 2 ) If the incapacity pension mentioned under Sub Article ( 1 ) is less than that or equal to the retirement pension to which the beneficiary is entitled , he shall receive the retirement pension . 32. Incapacity Gratuity A public servant who sustains employment injury of not less than ten percent ( 10 % ) without loss of capacity to work shall receive incapacity gratuity in the form of a lump sum . However , no gratuity shall be paid if the incapacity is assessed at less than ten percent ( 10 % ) 33. Amount of Incapacity Gratuity The amount of incapacity gratuity payable in accordance with the provisions of Article 32 here in above shall be equal to forty five percent ( 45 % ) of the basic monthly salary which he was receiving during the month preceding the occurrence of the injury times five years salary times the amount of percentage of injury sustained . PART SEVEN Survivors ' Pension and Gratuity 34. General 1 ) If any public servant : who is entitled to retirement or invalidity or incapacity pension , or ( h ) who has completed at least ten ( 10 ) years or service , but not separated from the service , or ( c ) who sustained employment injury dies a pension shall be paid to his survivors . 2 ) If a public servant who has not completed ten ( 10 ) years of service dies before he separates from the service , the surviors mentioned in Sub - Article 3 ( a ) and ( b ) of this Article shall receive gratuity . 3 ) The following shall be considered as survivors : a widow or widower , ( b ) children of the deceased who are under eighteen ( 18 ) years of age , ( c ) parents who were wholly or mainly supported by the deceased . Widow's or Widower's Pension 1 ) The amount of pension payable to a widow or widower shall be fifty per cent ( 50 % ) of the pension to which the deceased was or would have been entitled . 2 ) widow's or widower's pension shall be discontinued from the beginning of the month following remarriage . The African Law Archive