Colonial Rapacity

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    Colonial Rapacity and Political Corruption: Roots of African Underdevelopment and MiseryBy Emmanuel O. Iheukumere* and Chukuemeka A. Iheukumere**

    1. Introduction-Although Africa is well endowed with natural resources, it is a continent in distress.

    European colonial rapacity left the continent in disarray and deplorable shape upon independence.

    Independence appears to have simply resulted in rapacious echange of roles. !ow Africans suffer and

    die needlessly due to the bra"en and rec#less looting and hoarding of the public treasuries by greedy and

    unconscionably corrupt public officials. $orruption has compounded the in%ustice of the colonial legacy,

    severely impoverished the average African, left the few infrastructures in ruins, and robbed the populace

    of the benefits of their national resources.

    &. 'owing the seeds of social and economic misery- African countries under colonial rule.

    (. Independence from $olonial )ule !ew +eadership and the $ontinued Betrayal of a $ontinent.

    . he Effects of political corruption on African social and economic life.

    . he )ole of the /estern /orld in 0ostering olitical $orruption in Africa.

    2. otential /ays of Addressing olitical $orruption in Africa.

    3. $onclusions.

    ! Eaton 4 5c$lellan, hiladelphia, ennsylvania Ad%unct rof., emple 6niversity 7ames E. Beasley'chool of +aw $hair, 5inority Bar $ommittee of the ennsylvania Bar Association, B.A., summa cum laude,$larion 6niversity of ennsylvania 7uris 8octor, emple 6niversity 'chool of +aw. A fre9uent commentator inthe areas of civil litigation, his writings on affirmative action, informed consent, medical malpractice, prescriptiondrugs liability, and admissibility of scientific evidence, among others, have appeared in several law reviews and

    %ournals. :e dedicates this article to his mother $ecilia, and to the memory of his father, 7ames, both of who taughthim the value of hard wor# and honesty. :e also dedicates this article to the memory of his recently deceasedcousin $hu#wuma ;odwin s murderous and savage rule of the $ongo territory. In addition, thewriter ac#nowledges Adam :ochschild>s ecellent chronicle of colonial atrocities in Africa, particularly in the$ongo in his boo# ?=ing +eopold>s ;host.@ he writer is greatly indebted to these individuals for their #indsupport and encouragement his children-Emmanuel, 7r., 7ane, and 5arshall his siblings $hu#wueme#a,

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    6niversity of ittsburgh 5.A., 8u9uesne 6niversity, ittsburgh B.'.c, with honors, 'outhwest5issouri 'tate 6niversity. he author dedicates this article to his mother $ecilia, and to thememory of his beloved father 7ames. In addition, he dedicates this article to his children.0inally, the author than#s his co-author and brother Emmanuel, whose idea made this articlepossible.

    I"#RO$UC#IO"

    Although well-endowed with abundant mineral and human resources, Africa is a continent in distress. 1

    0irst, the continent was coloni"ed by Europeans who brutali"ed its inhabitants, &massacred any groups which dared

    to challenge their brutal rule,( and then siphoned the natural resources to Europe. 'econd, after looting the

    treasures of the continent, and sub%ecting its inhabitants to the most gruesome treatment ever visited upon a people,

    the various colonial powers granted independence to the scattered nations of that continent, without preparing the

    new rulers to manage their devastated economies and ethnic groups. In many instances, the departing colonial

    1'ee, e.g., /il :aygood, %ook Revie& %i' Men& (ittle People: #he (eaders )ho $efined Africa, byAlec )ussell, :E Bs formerly Daire 5obutu 'ese 'e#o,5alawi>s :astings =amu"u Banda, among others, while their people struggled and suffered under the swelteringin%ustice of crushing poverty and mismanagement. 'ee also 5ar# urner, Africans Off #ar'et in )ar onPoverty, 0I!A!$IA+ I5E' +ondon, 5ay 1C, 1, at C( highlighting the high cost of servicing the debts ofAfrican countries at the same time capital flight from the continent continues unabated and Conference AdoptsPlan to *alve African Poverty, :E 8AI+F F

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    powers perpetuated their rape of the continent through the imposition of constitutions which preserved the

    privileges of the immigrant European population at the epense of the native inhabitants. 2 !ot surprisingly, some

    of the new African leaders emulated the brutalism and savagery of the coloni"ers, and heaped misery, violence,

    and poverty upon their own.3 hese unconscionable Jleaders> pitted ethnic groups against ethnic groups to

    preserve their political power,Gand lived in shameless luury, while robbing their countries blind.

    he culmination of the debauchery of colonial rule, and the unpreparedness and greed of many early

    &CC1, Kol. 1&G, !o. 13, at pg. 13hereinafter, $ooper, :istory as ragedy observing that at the time ofindependence, the Belgians left the $ongoHa country seventy-si times the si"e of Belgium with ?%ust seventeenAfrican university graduates- and not a single lawyer, architect, engineer, or army officer among [email protected] to the commentator, ?Belgian leaders schemed to ensure that the country>s vast eploitable resources-copper, diamonds, minerals-remained in European hands.@ Id. 'ee also Abdullahi A. An-!a>im, #he Contin'entUniversality of *uman Ri'hts: #he Case of ,reedom of E+pression in African and Islamic Conte+ts , 11Emory Int>l +. )ev. &, 'pring 13?After a long history of encouraging and institutionali"ing Europeansettlement of =enya and the total sub%ugation of its native African population, Britain was finally forced to return

    the country to its own people with little preparation for democratic self-governance.@.

    2 'ee generally )ahman 0ord, $ommentL +aw, :istory, and the $olonial 8iscourseL8avies v. $ommissioner and Dimbabwe as a $olonial $ase 'tudy, :ow. +. 7. &1( 0all &CC1.

    3'ee, e.g., )./. 7ohnson, (ords of Misrule )ho Condemn Africa to )ar& ,amine& and #yranny ,:E I5E' of +ondon, 7anuary 1G, &CC1 0eatures 'ection,hereinafter, 7ohnson, +ords of 5isrulehighlighting the atrocities against the citi"ens, by former African leaders such as 5obutu 'ese 'e#o of the $ongo)epublic, then #nown as Daire under 5obutu, Idi Amin of 6ganda, self-proclaimed emperor 7ean Bedel Bo#assaof the $entral African )epublic, and 5acias !guema of E9uatorial ;uinea, among others. 'ee also, $ooper,:istory as ragedy, supra note describing in graphic detail, 5obutu>s horrific murder of the first rime 5inisterof the $ongo, atrice +umumba, with the help of the $.I.A. According to the account of +umumba>s senselessmurder, the young Honly thirty-si and idealistic rime 5inister was overthrown less than three months after

    assuming power, viciously beaten by 5obutu>s thugs in the presence of 6nited !ations diplomats who left him tohis unfortunate fate, and then eecuted by firing s9uad, along with two associates. he three bodies were thendismembered and burned. 'ee also :ochschild, supra note , at (C& observing that ?+ess than two months afterbeing named the $ongo>s first democratically chosen prime minister, a 6.'. !ational 'ecurity $ouncilsubcommittee on covert operations, which included $IA chief Allen 8ulles, authori"ed his H+umumba>sassassination.@ :ochschild continued, ?the 6nited 'tates saw to it that he H+umumbanever had a chance. +i#emillions of $ongolese before him, he ended up dumped in an unmar#ed grave.@id.

    G'ee, e.g., 7on 'wain, A 5ourney to Con'o Reveals a Re'ime Collapsin' into (alessness andA1surdity and a Country on the /lide, :E '6!8AF I5E' 6nited =ingdom, August 1(, &CCC hereinafter,'wain, )egime $ollapsingdescribing how former $ongolese tyrant 5obutu 'ese 'e#o eploited the ethnicdivisions in his country to amass untold wealth at the epense of the public 'ee also /illiam faff, Africa: Can a,ormula for /ta1ility and Pro'ress 1e ,ound6I!E)!AI

    (

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    African leaders, and their successors is the current situation in the continent where corruption is endemic, 1C and

    has thrust the overwhelming ma%ority of the populace into ab%ect poverty and suffering.

    his article eamines the role of corruption in the emasculation of African economies and the attendant

    impoverishment of the populace beginning from the colonial period and continuing to the present. /e contend

    that although colonialism, with its inhumanity and barbarism, robbed African countries of their natural resources,

    brutali"ed and humiliated the inhabitants, 11 and enthroned bra"en robbery through un%ust positive Jlaws> and

    Jtreaties>1&the corrupt practices and behaviors of African leaders since independence continues the brutali"ation of

    Africa3s (ast $ictators %os to $emocracy, :E !E/ F

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    the average African, and ensures his or her crushing poverty and hopelessness. $orruption among African leaders

    and officials in turn is then, unfortunately and regrettably, aided and abetted by the ban#ing and economic policies

    of the same colonial powers which initially heaped misery and savagery upon the continent, and helped ensure the

    despotism of some of the worst pretenders who branded themselves leaders.

    o support our contentions and conclusions, we eamine in depth, corruption in the form of licentious

    rapacity during European colonial rule,1( the etent of political corruption in many post independent African

    countries using published reports, studies, and surveys, and point out the level of looting of the public treasuries.

    /e then analy"e how these looting, and subse9uent transfer of the public resources to western countries have

    brought several African economies to the brin# of collapse. 0inally, we offer some suggestions for chipping away at

    the enduring cancer that is corruption.

    Although corruption, in the broader contet, includes colonial eploitation of African natural resources

    for the benefit of Europe, and the depraved treatment of Africans, 1 the #ind of corruption engaged in by various

    African leaders subse9uent to independence, has eacerbated the effects of the colonial legacy, and plunged the

    African continent further into economic ruin and social misery. olitical corruption in Africa after independence

    has turned the promise of a better life into a miserable present, and an uncertain future. It has impeded the fair

    administration of %ustice,1 contributed to unfair and une9ual treatment of the citi"enry, 12 and left the average

    1(Although the term Jcorruption> embraces ?the promise or payment of a benefit that induces a publicofficial to breach a duty pertaining to a significant community interest,@ 8avid :ess and homas /. 8unfee,/ymposium: ,i'htin' International Corruption 9 %ri1ery in the ; stCentury: ,i'htin' Corruption:APrincipled Approach #he CCom1atin' Corruption, (( $ornell Int>l +.7. (, &CCChereinafter, :ess and 8unfee, 0ighting $orruption, the definition of corruption is much broader. $orruptionincludes, among others, ?moral perversion,@ ?depravity,@and ?rottenness.@ 'ee /ebster>s 6niversal $ollege8ictionary )andom :ouse Inc. &CC1, at pg. 1G&. 6sing the broader definition of corruption, it is clear, as thisarticle will illustrate, that the colonial system was utterly corrupt.

    1'ee supra note 1(, and accompanying tet.

    1'ee, e.g., hilip $. A#a, "i'eria: #he "eed for an Effective Policy of Ethnic Reconciliation in the"e Century, 1 emp. Int>l 4 $omp. +. 7. (&3, (-2 0all &CCChereinafter, A#a, olicy of Ethnic)econciliationhighlighting the pervasiveness of corruption among the !igerian leadership, particularly themilitary regimes which have ruled !igeria for most of the time since independence, and noting their propensity forviolence against the citi"enry, and unfair administration of %ustice, culminating in former dictator and utterlycorrupt despot ;eneral Ibrahim Babangida>s annulment of a fair election presumably won by 5oshod Abiola.

    12'ee A#a, olicy of Ethnic )econciliation, supra note 1.

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    African without much hope. $ompounding the effects of corruption are the /estern ban#ing and financial

    interests which have assisted and continues to assist unpatriotic, 13 and corrupt and despotic African leaders in

    laundering their stolen proceeds,1Gwhile turning a blind eye to the terrible effects of political corruption.

    /O)I"- #*E /EE$/ O, CORRUP#IO": A,RICA" COU"#RIE/ U"$ER CO(O"IA( RU(E.

    Although corruption is a universal problem,1and has been in eistence for a very long time,&CEuropean

    coloni"ation, contrary to prevailing myth, failed to be9ueath democracy to African countries, but rather, left a

    legacy of authoritarian rule and plunder,&1and sowed the seeds for the vicious type of corruption now plaguing

    African countries.&& 6sing the pretet of bringing $hristianity and civili"ation to the Jnatives>&( European

    13/e posit that corrupt African leaders are not only a bane to their fellow citi"ens, but are, in the truesense of the word, unpatriotic moral midgets without conscience, and indifferent to the abysmal conditions of theircountries and sub%ects. 'ee /ebster>s 6niversal $ollege 8ictionary )andom :ouse, Inc. &CC1, at pg. GCdefining a patriot as ?a person who loves, supports, and defends his or her country and its interestsemphasis

    added. It is undisputable that it is in the interest of a nation to have well educated citi"ens, a well maintained andefficient bureaucracy, well maintained social and physical infrastructures, and a populace with a high standard ofliving. o the etent the rapaciousness of so-called African leaders has deprived Africans of these benefits, thesecorrupt and licentious Jleaders> are immeasurably unpatriotic.

    1G'ee, e.g., #he (ost %illions: #he Inside /tory of the *unt from (a'os to "e ?ork to -eneva foran African $ictator3s /tolen (oot, !E/'/EE= I!E)!AI

    &C'ee, e.g., =imberly Ann Elliott, Perspective: #he Pro1lem of Corruption: A #ale of #o Countries ,1G 7. Intl. +. Bus. &, & /inter 1G.

    &1'ee :ochschild, supra note , at (C1 ?the ma%or legacy Europe left Africa was not democracy as it ispracticed today in countries li#e England, 0rance, and Belgium it was authoritarian rule and plunder.@.

    &&his statement in no way implies that there is a benevolent type of corruption.

    &('ee, e.g., 5a#au 5utua, /ava'es& ictims& and /aviors: #he Metaphor of *uman Ri'hts, & :arv.Int>l +.7. &C1, &(-(2 /inter &CC1observing that although ?$olonialism was driven by ignoble motivesHpage&(2...ositivistsHincluding European missionaries developed an elaborate vocabulary for denigrating thesepeoplesHthe coloni"ed, presenting them as suitable ob%ects for con9uest, and legitimi"ing the most etreme

    2

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    coloni"ers instead brought barbarism and unspea#able savagery to the Africans. hrough brute force and greed, the

    coloni"ers ushered in slave labor,&divested the African of the ownership of his or her land and the resources

    therein, & enslaved men, women, and children,&2 and robbed the African of every once of dignity and human

    right.&3 /hile attac#ing the heinous Arab enslavement of Africans, European coloni"ers unleashed unimaginable

    cruelty against the African, which dwarfed the atrocities of the Arab slave raiders and traders &Gand rose to the level

    violence against them,all in the furtherance of the civiliBin' mission@the dischar'e of the hite man3s1urden.@emphasis supplied.

    &'ee generally :ochschild, supra note . 'ee in particular, page 1& where the author observes thatwhile +eopold grandly issued edicts banning the slave tradeHperhaps to burnish his duplicitious image as a greatchristian #ing and humanitarian he encouraged and had in place, a system which enslaved the $ongolese forcheap labor. 'ee also page 1&, where the author emphasi"ed that unli#e rotestant missionaries who hired andpaid the porters at their service ?the $ongo state-at +eopold>s specific order-used forced labor.@

    &'ee id. at 113.

    &2'ee, e.g., id. at 111 reiterating missionary and lawyer ;eorge /ashington /illiams> first handnarration of the Belgian $ongo state>s buying and selling of slaves. 'ee also id. at 121-2( describing in graphicdetail the #idnapping of men, women and children by +eopold>s officials in the $ongo for the epress purpose ofcompelling them to gather rubber pulp, a process described as so arduous and painful, since ?A gatherer had to drythe syrup-li#e rubber so that it would coagulate, and often the only way to do so was to spread the substance on hisarms, thighs, and chest,@ id. at 121. he author further describes the slavish control of the inhabitants whereverthe rubber vines grew as followsL

    /herever rubber vines grew, the population was tightly controlled. 6sually you had to get a permit fromthe stateH$ongo free state or company Hcorporation established by =ing +eopold, II of Belgium to run the$ongo free state agent in order to visit a friend or relative in another village. In some areas, you were

    re9uired to wear a numbered metal dis#, attached to a cord around your nec#, so that company agentscould #eep trac# of whether you had met your 9uota. :uge numbers of Africans were conscripted into thislabor armyL in 1C2, the boo#s of A.B.I.). alone, responsible for only a small fraction of the $ongo state>srubber production, listed forty-seven thousand rubber gatherers.

    &3'ee id. at 132 describing how indigenes of the $ongo were brought to Europe and placed on ehibit atworld fairs-%ust li#e animals. :ochschild describes in particular, the horrible fate of a $ongolese midget, s Bron Doo, where the helpless man was compelledto share his space with an orangutan. o compound the horror, "oo #eepers scattered bones on the floor around theman to give spectators the impression that he was a human eating savage. By the time a group of African-American ministers rescued Benga from the "oo, the eperience had left such a scare on Benga that he latercommitted suicide. Incredibly, and shoc#ingly, the promoter of the ehibit was a former resbyterian missionary.'ee id. 'ee also id. at 122 describing the parading of native $ongolese who failed to use a designated toilet, and

    the smearing of the faces of the hapless victims with ecrement.

    &G'ee id.at 1& noting that under the brutal rule of the $ongo free state ?soldiers Hof African descentand chiefs ali#e were flogged or hung for the slightest offense. hey HAfrican soldiers who mutinied due to theinhumane rule of =ing +eopold>s men in the $ongo free state spo#e of one white officer who shot sity soldiersHAfricans in a single day because they refused to wor# on a 'unday, and of another who ?with his own handspoured salt and pepper on the bloody wounds made by the chicotteHa wipe made from the dried hide of ahippopotamus and ordered the sic# from his post thrown alive into the +ualaba )iver.@?

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    of a holocaust.&

    rior to the Berlin $onference of 1GG, which carved up Africa li#e a piece of ca#e for the European

    nations, ma%or coloni"ers such as Britain, ;ermany, 0rance, ortugal, and little, but profoundly vicious Belgium, (C

    had already established enclaves in various African territories with the sole aims of plundering the continent>s

    resources for the benefit of Europe, moral pretenses notwithstanding. (1 Also, prior to the Berlin $onference, the

    6nited 'tates, perhaps unwittingly, had given its imprimatur to the rape of the continent by the murderous and

    savage Belgian monarch, =ing +eopold II.(& Although prior to the arrival of European coloni"ers, Africans had

    made wars against each other, and engaged in customary practices that were, by any ob%ective measurement,

    atrocious, and of no redeeming value,((the arrival of European coloni"ers ushered in the absolute degradation of

    the African,(and a fast paced destruction of the African family. 0or eample, during the period #nown as the

    &'ee id. at &((concluding, based on a 11 official Belgian government commission findings,ethnographic studies, and the 1& territory wide census of the $ongo, that about ten million $ongolese dieddirectly or indirectly as a result of +eopold>s brutish rule in the territory. .

    (CBelgium is less than half the si"e of /est Kirginia. 'ee :ochschild, supra note , at (2.

    (1'ee id. at G&-G3.

    (&'ee id. at 3-G& observing that through the efforts of Alabama>s 6.'. 'enator 7ohn yler 5organ, aformer $onfederate brigadier-general, and the lobbying activities of former 6.'. 5inister to Belgium underresident Abraham +incoln, Hsee page G, :enry 'helton 'anford, the 6nited 'tates, during the presidency of$hester Arthur, became the first country to recogni"e +eopold>s claim to the $ongo Hpage G1.

    (('ee, e.g., :. 5urray :ofmeyr, Christian Mission and Colonialism in /outhern Africa and AfricanResponse: /ome Case /tudies, 1 Emory Int>l +. )ev. 1C&, 1C&hereinafter, :ofmeyr, $hristian 5ission and$olonialismnoting the observations of an African born missionary =laas =oen about some of the deviouspractices among the indigenous people, such as the #illing of the second child ma#ing up a twin ?even when thefirst was born dead,@ the worshiping of animals, such as apes, which allegedly contained the spirits of theworshippers> ancestors and the marriage of girls as young as nine years old by old men.

    ('ee, e.g., :ochschild, supra note , at 1&C-&1 noting the emotional and physical degradation and utterhumiliation of the African at the hands of the coloni"ers. !ot only was the African mercilessly lashed, severelypunished for the most minor infraction, and literally wor#ed to death, he or she was also demoni"ed andassiduously treated as less than a full human being. he European coloni"ers held the opinion that ?Africans wereinferior beings la"y, uncivili"ed, little better than animals,@id. at 1&1. 'ee also hilip $. A#a, #he Military&-lo1aliBation& and *uman Ri'hts in Africa , 1G !.F.+. 'ch. 7. :um. )ts. (21, (3 hereinafter, A#a, :uman)ights in Africa?$olonial rule the way it unfolded in Africa has several features that negated even rudimentarynotionHs of human rights.@.

    G

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    rubber terror, husbands were compelled by force of arms to abandon their wives and children for etremely

    etended periods of time in search of wild rubber for the benefit of =ing +eopold II, and his minions. ( o ma#e

    matters worse, +eopold>s men in the $ongo would often hold the women and children hostage under the most

    inhumane and barbarous conditions until the men provided the demanded amount of rubber. (2 /ith regard to

    mining, husbands were forced to mine deep into the earth under life threatening conditions for etended periods of

    time while separated from their families.(3 hese forced labor practices had the predictable effect of destroying the

    closeness and cohesiveness of the affected households. eace of mind became a rare commodity, since the natives

    #new that the allegedly Jcivili"ed> strangers could murder both adults and children for the most minor

    infraction. (G

    'ignificantly, while the Africans received pittances, when paid at all for their labors, or wor#ed or slaved

    to procure the abundant mineral resources, ( many European administrators of coloni"ed provinces amassed ill-

    gotten wealth at the epense of the impoverished and disenfranchised locals. C E9ually reprehensible, almost none

    ('ee :ochschild, supra note , at 12( relating the estimate by a colonial administrator in the $ongoterritory that in order to fill their 9uota ?rubber gatherers had to spend twenty-four days a month HapproimatelyGCM of their time in the forest, where they built crude cages to sleep in for protection -not always successful-against leopards.@.

    (2'ee id. at &(C ?6ntold thousands of people, women, children, and the elderly, died as hostages.'oldiers #ept them in dirt compounds, often in chains, feeding them little or nothing until the men of a villagebrought in the demanded amount of rubberNsomething that might ta#e wee#s. In one stoc#ade in 1G, prisonerswere found to be dying at the rate of three to ten a day.@

    (3'ee id. at &3G-3. Among those mines to which hapless Africans were conscripted to wor# in were theheavily guarded $ongo mine at 'hin#olobwe, which allegedly produced more than eighty percent of the uraniumused in the atomic bombs dropped on :iroshima and !agasa#i during /orld /ar II. 'ee id. at &3.

    (G'ee id. at &( describing the senseless bloodletting in the $ongo. According to three particularlyhorrific accounts, one $ongo free state official named )ene de ermentier had the ignoble and sadistic reputationof ordering the beheading of female prisoners for the simple offense of failing to properly sweep a courtyard. Inanother incident, ?wo 0orce ubli9ue officers Hthe 0orce ubli9ue was the army raised to protect the $ongo freestate, $lement Brasseur and +eon $erc#el, once ordered a man hung from a palm tree by his feet while a fire waslit beneath him and he was coo#ed to death.@ Fet, in another incident ?wo missionaries found one post whereprisoners were #illed by having resin poured over their heads, then set on fire.@id.

    ('ee generally 7oseph $onrad, *eart of $arknessenguin Boo#s. 6.'.A. 1 at3-3 noting the

    net to nothing the natives got for their hard and miserable labor.

    C'ee, e.g., :ochschild, supra note , at 1(2-(3L0or a white man, the $ongo was also a place to get rich and to wield power. As a district commissioner,you might be running a district as big as all of :olland or Belgium. As a station chief, you might be ahundred miles away from the net white official you could levy whatever taes you chose in labor, ivory,or anything else, collect them however you wanted, and impose whatever punishments you li#ed...the$ongo offered a chance for a great rise in status. 'omeone fated for a life as a small-town ban# cler# or

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    of the profits generated from the mineral resources were invested to educate and evangeli"e the Jnatives>. 1 )ather,

    it appears that each time the African 9uestioned the inhumanity of the coloni"ers, the coloni"ers resorted to the

    most etreme means of enforcing their unbridled rule, such as massacres and genocidal campaigns. &

    $onsider, for eample, the ;erman massacre of the :ereros in 'outh Africa. /hen a misunderstanding

    arose between the ;erman coloni"ers and the :ereros, the ;ermans under =aiser /ilhelm II, deliberately set out

    to eterminate the :ereros. A ;erman general, with the full support of the ;erman leadership, gave the order to

    annihilate the :ereros, both men, women, and children. (After massacring the :ereros, the ;ermans herded the

    unfortunate survivors into essentially concentration camps, and then allocated them as slave laborers to ;erman

    companies, some of which apparently, still eist. he ;erman etermination campaign against the :ereros

    resulted in the drastic reduction of their population from approimately GC,CCC to 1,CCC by 1C2, a reduction of

    immense genocidal dimensions. 0ollowing the British ta#eover of the previously ;erman colonial territory, the

    British government commissioned its colonial administrator for 'outh Africa, E.5.' ;eorge, to investigate the

    charges of etermination by the ;ermans.2In a report dubbed the JBlue Boo#> the British administrator not only

    documented the ;erman etermination of the :ereros, but also discovered that having eterminated the vast

    ma%ority of the :ereros, the ;ermans stole their lands, forbade them from their natural occupation of maintaining

    plumber in Europe could instead become a warlord, ivory merchant, big game hunter, and possessor of aharem.

    1'ee id. at 11C noting lawyer and missionary, )ev. /illiams> complaint to =ing +eopold about the$ongo free state thusly ?here were no schools and no hospitals ecept for a few sheds ?not fit to be occupied by ahorse@?.

    &'ee notes & and 11 supra, and accompanying tets. 'ee also :ofmeyr, Christian Mission andColonialism, supra note ((, at 1C2-3 highlighting the British>s deliberate and callous provocation of a war withthe Dulus during the late part of the 1 thcentury, which resulted in 1&,CCC deaths.

    ('ee, e.g., 5asland, #he ,or'otten -enocide, supra note &observing that once the ;erman war of1C to ?eterminate the :erero herders...began, ;erman officials made their intentions clear.@ he writer 9uotesthe ;erman commander of the war, ;en. +othar von rotha, whom =aiser /ilhelm II hand pic#ed for theslaughter as saying ?I find it most appropriate that the nation H:erero nation perish.@ According to the article,another ;erman officer documented in his diary ?/e had been eplicitly told beforehand that this dealt with theetermination of a whole tribe nothin' livin' as to 1e spared.@emphasis added.

    'ee idaccording to the writer ?In wretched camps by the seaports, the :erero died in droves ofmalnutrition, overwor# and disease. he wor#ers wore copper dis#s around their nec#s bearing numbers@.

    'ee id.calling the victims of the ;erman massacre ?the genocide victims history all but forgot.@

    2'ee, e.g., %lue %ook, supra note &.

    1C

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    farms and live stoc#, and then consigned the survivors to forced labor for the benefit of the replacement ;erman

    farmers, who converted the :ereros> lands to theirs.3 :owever, despite the documentation of this ;erman

    atrocity, which certainly ran#s as crimes against humanity, =ing ;eorge KI of Britain, indicative of the barbaric

    collusion of the colonial powers to the detriment of the coloni"ed, gave in to pressures from the ;erman, and 'outh

    Africa>s white governments, and ordered the destruction of the Blue Boo#. G But in loc#step fashion with the

    Biblical teaching that there is nothing hidden that will not be revealed, a copy of the Blue Boo# was recently

    discovered with its findings of horrors. C&'ee )onald =oven, "ational Memory: #he $uty to Remem1er& the "eed to ,or'et *istoricalMemory in ,rance /pecial ,eature 'ociety, Kol. (&, !o. 2, pg. & 'eptember 1assailing the 0rench,particularly the government, for the habit of hiding the truth about 0rench atrocities, and defeats from the public.

    ('ee id.

    11

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    appropriately, by con9uest, within European legal systems, vested the con9uering colonial power with legal right to

    the land previously occupied by the natives and all the natural resources therein. 2& he courts put their legal

    imprimatur to this legal subterfuge by declaring this concept a universally recogni"ed principle, 2( ignoring the

    older principle, previously deemed universal, of ownership by first possession.2

    Although the British colonial rule in Africa was perhaps, not as vicious as that of the ;ermans and the

    0rench, British rule nevertheless, was brutal, inhumane and roguish. 2 he British enthroned a divide and con9uer

    system which pitted ethnic groups against each other in the interest of preserving the continent>s vast natural

    resources for the benefit of the British empire.22

    :owever, the most brutal, vicious, licentious, and genocidal eample of colonial rule in Africa certainly is

    the Belgian and =ing +eopold II>s rule of the area that came to be #nown as the $ongo free state. Although the

    term ?free state@ perhaps con%ures up the image of a territory that was free of the ravages of its time, nothing could

    be farther from the truth. =ing +eopold II of Belgium, a reprobate by even the standards of his own era, 23whose

    lust for etremely young teenage girls bordered on pedophilia, 2Gschemed to ac9uire an undeserved reputation as a

    2&'ee id. 'ee also, 7esse 8u#eminier and 7ames E. =rier, Property'econd. Edition, 1GG., at 1&-1.

    2('ee 5ohnson v. M3Intosh&1 6.'. G /heat (.

    2'ee Epstein, Possession as the Root of #itle , 1( ;a. +. )ev. 1&&1, 1&&& 13, cited in 8u#eminierand =rier, supra note 2&, at1(.

    2'ee, e.g. 5ar# s payment for a steady supply of young prostitutes, some as young as ten.

    2G'ee id. at &&& ?+eopold had long had a well-#nown taste for etremely young women,@ some as youngas ten Hsee pg. GG and lost his head over a siteen year old prostitute, $aroline, whom he lavished epensive giftson, including her installation ?in a grand mansion, the Killa Kanderborght, across the way from the royal compleat +ae#en, and built a pedestrian bridge over the street so that he could slip across at will for visits.@.

    1(

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    philanthropist and great humanitarian. 2 :aving fooled the British, the 0rench, ;ermany, and the great emerging

    power-the 6nited 'tates, about his true and dastard intentions for the $ongo, +eopold established himself in the

    eyes of willing European and American media as a $hristian monarch stridently opposed to the vicious Arab

    enslavement and mistreatment of Africans. 3C

    $apitali"ing on the European and American hatred of the Islamic Arabs, +eopold gained the favor of

    most European and American citi"ens, who may have considered themselves good $hristians intent on supporting

    what was perceived as +eopold>s noble endeavor to rescue Africans from the evils of slavery. 31 /ith the support of

    apparently well-meaning, but naive throngs behind him, +eopold, with the full assistance of the eplorer 5orton

    'tanley, who was greatly hailed as among the greatest of African eplorers, 3&and the former American consul to

    aris, :enry 'helton 'anford lobbied the 6nited 'tates resident $hester Arthur, and $ongress to recogni"e his

    claim to the $ongo.3( +eopold and his cohorts framed his future endeavor in the $ongo as a purely humanitarian

    underta#ing to rescue the Jnatives> from Arab enslavement, and then, to set up states with Africans in charge of

    their destiny.3 +eopold found a willing and supportive audience with the rabidly racist 6.'. 'enator 5urray from

    the 'tate of Alabama, who helped shepherd a bill through $ongress lauding +eopold>s intended mission in the

    $ongo.3 hrough deliberate falsehoods about his intentions in the $ongo, and epensive and sustained lobbying

    2'ee id. at &-.

    3C'ee id. at &-(.

    31'ee id.

    3&Id. at 2&-3.

    3(Id. at 33-G&.

    3'ee id. at 23noting how +eopold fooled the Europeans and Americans with the illusion that the $ongowould be a ?confederation of free negro republics,@ with Africans ruling under the noble guidance of a benevolentBelgian #ing.

    3Id. at GC.

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    +eopold convinced the American government to become the first government to recogni"e his claim to the

    $ongo.32 :aving obtained American recognition, +eopold schemed to convince the ;ermans and other European

    powers to follow suit. At the Berlin $onference European powers put their imprimatur to +eopold>s claim to the

    $ongo, a territory ?bigger than England, 0rance, ;ermany, 'pain, and Italy combined...more than seventy-si

    times the si"e of Belgium itself.@33

    After cementing his claim to the $ongo, +eopold established forced labor in the $ongo, 3Gand went with

    unmitigated greed after the highly profitable trade in ivory. ;etting ivory, of course, re9uired the #illings of

    elephants. hus, was born the mass slaughter of African elephants for the personal enrichment of +eopold. 3

    'everal years after the mad scramble for ivory had lessened a little bit, +eopold found a new source of wealth in the

    $ongo,i.e., rubber pulp for eport to Europe during the heyday of the industrial revolution. Because of the

    difficulty inherent in harvesting the pulp from the rubber vines, not many people were willing to engage in that

    vocation.GC But since +eopold regarded the $ongo and its African inhabitants, and the entire mineral resources as

    his own personal property, +eopold encouraged the enslavement of the inhabitants of the territory, and epanded

    the system of forced labor.G1 /ith the inhabitants as either slaves, or forced laborers, +eopold>s subordinates

    compelled the helpless Jnatives> to collect rubber pulp under the gun, and under the constant threat of bloody

    whippings with the chicotte, a lash made from the raw hide of the hippopotamus. G& 8ue to +eopold>s murderous

    32Id.at G1.

    33Id. at G3.

    3G'ee id. at 11G-1&.

    3Id. at 11G?As the 1GCs began, the wor# whose sanctity +eopold pri"ed most highly was sei"ing allthe ivory that could be found. $ongo state officials and their African auiliaries swept through the country on ivoryraids, shooting elephants, buying tus#s from villagers for a pittance, or simply confiscating them. $ongo peopleshad been hunting elephants for centuries, but now they were forbidden to sell or deliver ivory to anyone other thanan agent of +eopold.@.

    GCId. at 121describing the difficulty of harvesting rubber vines thusly ?!o payments of trin#ets or brasswire were enough to ma#e people stay in the flooded forest for days at a time to do wor# that was so arduous-andphysically painful.@.

    G1'ee id. at 12C-2(.

    G&'ee :ochschild, supra note , at 1&C describing the chicotte as ?a whip of raw, sun-driedhippopotamus hide, cut into a long sharp-edged cor#-screwed strip. 6sually the chicotte was applied to thevictim>s bare buttoc#s. Its blows would leave permanent scars more than twenty-five stro#es could meanunconsciousness and a hundred or more-not an uncommon punishment-were often fatal.@.

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    greed for rubber, and his system of compensation which rewarded European underlings with commissions, in

    addition to fied salaries, based on the amount of rubber collected within the areas under their control, cutting off

    the hands and ears of the natives in other to induce a greater supply of rubber became sanctioned official policy, G(

    as well as the #idnapping of the natives for forced rubber supply. G =idnapped married women were chained by

    the nec#, and held as hostages under armed guards to compel their husbands to go into the forest to gather wild

    rubber for the benefit of +eopold.G Even little children were held as hostages, and sometimes their hands were cut

    off to force their fathers to brave the harsh elements of untamed and thic# forests to gather wild rubber. G2

    he reign of terror +eopold introduced into the $ongo free state decimated countless number of entire

    villages, and encouraged the murderous villainy of +eopold>s assistants such as +eon )om, a district administrator

    in the $ongo, who too# pleasure in #illing the natives for the slightest infringement, and decorated his garden with

    a row of about twenty-one severed African heads.G3

    /hile +eopold>s reign of terror was engulfing the $ongo, none of the so-called missionaries or other

    Europeans and Americans who were witnesses to the unfolding genocide had the courage to tell the rest of the

    G(Id. at 12 ?the severing of hands was deliberate policy, as even high officials Hof the $ongo free statewould later admit.@. :ochschild 9uoted one $ongo free state official $harles +emaire as confessing after hisretirement ?As soon as it was a 9uestion of rubber, I wrote to the government, Jo gather rubber in thedistrict...one must cut off hands, noses and ears.@?9uotation in the original.

    G'ee id.noting the official sanctioning of ?hostage-ta#ing.@. In addition, :ochschild observed ?If avillage refused to submit to the rubber regime, state or company troops or their allies sometimes shot everyone insight, so that nearby villages would get the message.@

    GId. at 121 noting among the official practice of ta#ing women and children as hostages to compel themen to gather rubber ?@If you were a male villager, resisting the order to gather rubber could mean death for yourwife. 'he might die anyway, for in the stoc#ades food was scarce and conditions were harsh.@. :ochschildobserved that oftentimes, the soldiers guarding the #idnaped women would unchain and then rape them.id. at 12&.

    G2'ee id. at 121.

    G3Id. at 1. 'ee also id. at 1 describing a letter the governor general of the $ongo free state sent

    bac# to Brussels, Belgium at the time +eon )om was station chief at 'tanley 0alls complaining about ?some agentswho ?have the reputation of having #illed masses of people for petty reasons.@?. 'ee also 'wain, Re'imeCollapsin', supra note Gin addition to assailing the rapacious rule of the late $ongolese post-colonial dictator,5obutu 'ese 'e#o, the writer reiterated the unfortunate colonial history of the $ongo, noting ?he barbarism ofthe #ing>s H=ing +eopold, II, of Belgium men was une9ualed even by the ruthless colonial standards of the day.:uman mutilation was practiced by the #ing>s men to account for every cartridge fired. hey hac#ed off andsmo#ed the hands, feet and private parts of the victims, presenting them to their commanders as evidence they haddone their %ob well.@.

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    world about +eopold>s murderous and rapacious rule in the $ongo until the African-American minister, lawyer,

    %ournalist, and historian, ;eorge /ashington /illiams went to the $ongo, and horrified by what he witnessed,

    penned an open letter to =ing +eopold II, which letter /illiams also sent to newspapers in the 6nited 'tates and

    Europe.GG /illiams eposed the enslavement, murder, and rape of Africans in the $ongo, and the utter falsity of

    +eopold>s claims about the benevolence of his rule in the $ongo. G After /illiams> horrifying revelations, which

    included witnessing the enslavement, rape, torture, and unmitigating humiliation of the Africans, Cothers such as

    the African-American missionary and eplorer, )ev. /illiam :. 'heppard, British consul and Irish patriot, )oger

    $asement, African businessman :e"e#iah Andrew 'hanu-originally from the present day +agos, !igeria, British

    investigative %ournalist, and later, member of parliament E.8. 5orel, Baptist missionaries )ev. 7ohn :arris and his

    wife, Alice, and other men and women of goodwill, continued, at the ris#s of their lives and livelihood, the

    revelation of +eopold>s sadistic hegemony in the $ongo. 1 )egrettably, by the time +eopold was compelled to

    transfer his Jownership> of the $ongo to the Belgian government at etremely profitable terms, &an estimated ten

    million $ongolese, a figure greater than the number of 7ews #illed under !a"i ;ermany>s e9ually heinous

    atrocities, had died as a direct or indirect result of +eopold>s genocidal rule. ( Incredibly, and unfortunately, the

    brutali"ation and humiliation of the $ongolese, with the eception of officially sanctioned enslavement, continued

    GG'ee :ochschild, supra note , at1C-11.

    G'ee id. at 111 containing /illiams> observations about the cruel treatment and murder of Africans.:e related his observations of white officers ?shooting villagers, sometimes to capture their women, sometimes to

    intimidate the survivors into wor#ing as forced laborers, and sometimes for sport.@. /illiams> account contains aparticularly chilling and haunting disregard for the life of the African displayed by the coloni"ers. According tohim, on one occasion ?wo Belgian Army

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    under the Belgian government until $ongolese independence in 12C.

    $olonial rule decimated the populations and structures of the African family,and epropriated the vast

    resources of that continent for the benefit of Europe. 5assive statutes, buildings, museums, and other evidence of

    material wealth, can still be found in many European cities from Belgium to +ondon, all made possible by the

    blood and sweat of the mistreated, humiliated, and ultimately, forgotten throngs of Africans during colonial rule. 2

    It is indeed difficult to eamine the colonial period and find evidence of pure humanitarianism. 3 Although many

    missionaries went to Africa with a sincere desire to spread the gospel and etend $hristian love and charity, and

    many sacrificed their lives for the cause, their ob%ectives were constantly thwarted by the brutal regimes of leaders

    such as +eopold, whose underlings had no 9ualms #idnapping boys and girls from mission stations, G thereby

    'ee om 5ba#we, Physician *eal #hyself Around Africa@Africa%el'ium %rief Article , !E/A0)I$A!, 7anuary 1, &CC&, at 1hereinafter, 5ba#we, hysician :eal hyself noting criticisms againstBelgium>s stance of eercising universal %urisdiction against foreigners in the prosecution of human rights abuses?wherever they were committed,@ while ignoring its own role in the mass #illings of the $ongolese during colonialrule. Although we concur with, and in fact applaud Belgium>s current sensitivity to human rights abuses,wherever they occur, it is clear that Belgium>s colonial rule was mired by repression and unbridled cruelty againstthe African colonial sub%ects. Belgium>s continued refusal, therefore, to even ac#nowledge its active participationin the genocide of its African sub%ects in the $ongo while claiming a moral and legal right under universal

    %urisdiction to prosecute crimes against humanity, smac#s of sheer hypocrisy.

    'ee, e.g., A#a, :uman )ights in Africa, supra note (, at (GC observing that the whole process Hofforced labor during colonial rule removed great numbers of men from rural life, turned farmers into wage-wor#ersand ruined rural stability and peace.@.

    2'ee e.g., :ochschild, supra note , at &(-.

    3'ee, e.g., A#a, :uman )ights in Africa, supra note (, at (G1 ?In sum, European colonial rule inAfrica was mar#ed by the abuse of Africans> individual and collective rights... It also left in its wa#e negativelegacies in politics, economics, and social lives with ruinous conse9uences for human rights in Africa.@.

    G'ee, e.g., :ochschild, supra note , at 1&-&2 noting the angry observations of a 'wedish missionary,

    $.!. Borrisson, that an official of the $ongo free state, a Belgian named Eugene )ommel ?imprisoned womenwhen the people refused to transport Hsupplies and to sell him goods below mar#et prices...:e was not ashamed tocome by our station Hmissionary station and abduct our school girls...and treat them in despicable ways.@. hemissionary continued, that one day, he and another missionary ?went to a neighboring village and helped releasethree poor women whom his H)ommel>ssoldiers had imprisoned because one of them had as#ed for the return of astone %ug which had been ta#en from her.@ id. hus, in addition to the bra"en abduction of school girls frommissionary houses, and presumably, raping them, =ing +eopold>s minions in the $ongo also engaged in shamelessacts of robbery, among other vices.

    1G

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    ma#ing it almost impossible for the Jnatives> to align themselves with a religion to which their cruel oppressors

    were identified with.

    In achieving the aims of their con9uests the colonial rulers left the inhabitants of the coloni"ed African

    territories, particularly the few elites, with the unmista#able impression that all that mattered was power and the

    audacity to use it for personal gains to the detriment of the populace.1CC he colonial rulers also left the

    unmista#able impression that force e9uals right. 1C1

    he lessons of enrichment through power ac9uisition and brute force was not lost on the Africans battling

    colonial rule. Although most of the nationalists such as =wame !#rumah of the $oast, renamed ;hana upon

    independence, =enneth =aunda of Dambia, 7omoh =enyatta of =enya, and 7ulius !yerere of an"ania, among

    others, arguably, had the noble intentions of casting off the colonial yo#e, and improving the lots of their fellow

    Africans, many soon adopted the greed and violence of the departing coloni"ers upon independence. In addition,

    contemporaries and subse9uent leaders such as 7oseph 8esire 5obutu, later renamed 5obutu 'ese 'e#o, of the

    $ongo )epublic, named Daire under 5obutu, 0eli :ouphouet-Boigny of the Ivory $oast, 7ean Bedel Bo#assa of

    the central African )epublic, who later dubbed himself emperor, and 5acias !guema of the E9uatorial ;uinea

    internali"ed the lessons of brute force and power ac9uisition so embedded in the colonial systems. 1C& his core of

    'ee generally :ofmeyr, Christian Mission and Colonialism, supra note ((, at1C3&-3(.

    1CC'ee A#a, :uman )ights in Africa, supra note (, at (3 ?he entire architecture of colonial rule,li#e that of military rule down the road in the continent, was built and maintained solely and completely on na#edforce@.

    1C1'ee id.

    1C&'ee, e.g., A#a, :uman )ights in Africa, supra note (, at (G3 highlighting the abusiveness andegregiousness of the regimes of 7ean-Bedel Bo#assa and 0rancisco 5acias !guema ?Bo#assa brutally murderedover 1CC schoolchildren for the ?political offenses@ of defying his orders and mouthing ?death to the Emperor.@0ollowing an unsuccessful coup against his government, a thoroughly insecure 5acias !guema perpetrated roundsof non-stop purges, carried out political eecutions of persons he suspected opposed his regime, and caused theeile of over 1CC,CCC in a population of approimately (CC,CCC people.@9uotations on political offenses and deathto the emperor in the original, internal citations omitted. 'ee also, :oward /. 0rench, (es ,au+ Complotsd3*ouphouet@%oi'ny: #he ,ake Plots of *ouphouet %oi'ny:Revie Hof boo# of same title written by 'amba

    8iarra, 0

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    Jleaders> and others of their il# appeared to have prepared themselves upon independence to continue the looting of

    their countries> resources begun under colonial rule.

    I"$EPE"$E"CE ,ROM CO(O"IA( RU(E:"E) (EA$ER/*IP A"$ #*E CO"#I"UE$%E#RA?A( O, A CO"#I"E"#.

    Independence brought with it a sense of relief from colonial oppression and barbarism, and the hope ofa

    better future for the newly liberated peoples of Africa. 1C( Independence meant that the African now controlled his

    or her destiny, and could en%oy the abundance of the natural minerals under the African soil, so the thought went.

    $iti"ens must have danced in the streets of the newly independent countries, and sung the praises of the indigenous

    leaders who had dared to oppose the oppressors and eventually win independence for their countries. Illiterate

    parents must have loo#ed with pride and optimism to the day when their children would obtain the educational

    benefits denied them under colonial rule. eople in the villages must have re%oiced at the prospect of electrification

    and pipe borne water for their hamlets, while city fol#s must have bristled with hope and high epectation at the

    prospect of paved roads, central sewer systems, e9uipped and fully staffed high schools and universities. In all,

    both the city and rural fol#s must have loo#ed to a better future governed by leaders who had their interests at

    heart, and with whom they could relate.

    he epectations of the people for a better life after many African countries gained independence in the

    1Cs and 12Cs were 9uic#ly replaced with sectional violence, 1C and the rise of military dictatorships. 1C'oon

    nations became ethnic enclaves within states. In !igeria, for eample, sectional violence, encouraged by the

    leaders of the regional political parties formed along ethnic loyalties, soon became the order of the day. 1C2 his

    1C('ee, e.g., A#a, *uman Ri'hts in Africa, supra note (, at (G&noting, for eample, the renewedhope for improved human rights in Africa which accompanied the achievement of political independence.

    1C'ee id. at (GG-G.

    1C'ee id. at C2 ?$oups d> etats and military rule became a feature of African politics %ust about the

    moment African countries became independent,@ additionally noting ?By the late 12Cs, about two-fifths ofAfrican states had come under military rule and coups had effectively replaced elections as a method of changinggovernment in the continent.@.

    1C2'ee hilip $. A#a, #he D$ividend of $emocracy: AnalyBin' U./. /upport for "i'erian$emocratiBation, && Boston $oll. hird /orld +. 7. &&, && 'pring &CC&hereinafter, A#a, 8ividend of8emocracy observing that ?0rom the outset Hof political independence, the H!igerian political system cameunder severe stress brought about by ethnic rivalry.@.

    &C

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    culminated in political violence, assassinations and counter assassinations, and a near collapse of the newly

    independent nation.1C3 In addition, accusations of public embe""lement, nepotism, and waste of public resources

    reached a deafening crescendo. 'ei"ing the emerging sense of free for all as an ecuse, the military stepped in

    with a bloody military coup in 7anuary 122. 1CG An e9ually bloody counter military coup too# place si months

    later.1C he resulting uproar and violence led to the !igerian-Biafran civil war which estimatedly claimed more

    than two million lives in the ensuing bloodbath, most of them Ibos and other groups from the eastern part of

    !igeria11Cand decimated the little physical infrastructure in eistence shortly after the country>s independence. 111

    As conflicts were brewing in !igeria, other newly independent African countries, such as ;hana and the

    $ongo )epublic, began to descend into corruption, and sectional rivalry. In the case of !#rumah of ;hana, his

    fiery nationalism which had helped lead his country to independence, soon gave way to arrogance and a demand

    for godli#e respect from his fellow citi"ens.11& In 122, after nine years of increasingly autocratic rule, first, as

    rime 5inister, and then as resident for life, !#rumah was overthrown in a military coup. 11( After his overthrow,

    evidence surfaced that in addition to his sway over his country>s affairs, !#rumah had enriched himself to the tune

    of millions of dollars at the young nation>s epense.11 !#rumah was banished into eile by the new military

    1C3'ee, e.g., A#a, Policy of Ethnic Reconciliation, supra note 1, at (((.

    1CG'ee id.

    1C'ee id.

    11C'ee id.

    111'ee id. at ((( observing ?he Biafran war of 123-3C is ran#ed as ?the bloodiest civil war of the &C thcentury.@ he conflict consumed what precious little physical infrastructures the country accumulated over itsbarely seven years of independenceas of the date the war began. It claimed an estimated two million lives, mostof them Igbos and other Easterners trying to secede from !igeria and form a separate independent )epublic ofBiafra.@9uotation in bloodiest civil war of the &C thcentury in the original, internal citation omitted.

    11&'ee, e.g., %ush #ele'raph on African /tatesmen, :E 8AI+F E+E;)A: ,!ovember , 12,at pg. &1 hereinafter, Bush elegraphobserving that soon after becoming the leader of the newly independentcountry of ;hana, !#rumah as#ed his followers to refer to him as

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    dictatorship. 11 But over the years the new leaders of ;hana have not done better to eradicate corruption. 112

    5eanwhile, in the $ongo )epublic, a young colonel named 7oseph-8esire 5obutu, chief of staff to the

    new and first rime 5inister atrice +umumba, with the help of the $entral Intelligence Agency ?$IA@, sei"ed

    power.113 /ith the approval of 6.'. resident 8wight 8. Eisenhower, 5obutu butchered the e9ually young, and

    idealistic +umumba.11G

    112'ee, e.g., ;eorge B.!. Ayittey,*o the Multilateral Institutions Compounded Africa3s EconomicCrisis, (C +aw 4 ol>y Int>l Bus. G, G 'ummer 1hereinafter, Ayittey, 5ultilateral Institutionsstressing?In )awling>sHresident 7erry )awling ;hana, people are employed or promoted not because they deserve- or are9ualified for the posts, but because they are relatives, tribesmen, party members or friends. hose ;hanaians whodo not fall in any of these categories pay huge bribes to get employed or promoted, or are left to suffer androt...ublic properties or assets-vehicles, buildings, businesses, machinery, even ships-are sold out to partymembers, friends, relatives, etc. for peanuts. Almost all the P!8$Hparty then in power top people are alleged tohave put up mansions, each costing hundreds of millions of cedis.@

    113'ee Pro1lems ith Current U./. Policy, 0s H$ongo>s first-ever democratic election.@.

    11'ee 'wain, )egime $ollapsing, supra note G3.

    1&C'ee id.

    1&1'ee %ush #ele'raph&supra note 11&.

    &&

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    of the $ongo as his personal property, and dealt with the nation>s public treasury as his piggy ban# by continuously

    stealing enormous amounts from the public treasury, allegedly to the tune of billions of dollars. 1&& Even though

    the Belgians had left behind very few infrastructures that could benefit the new nation, and left the populace

    severely uneducated, 5obutu, %ust as =ing +eopold had done decades before him, failed to invest the public>s

    money into the moderni"ation and epansion of the public infrastructures necessary for a better standard of living

    for his people. 0urther, 5obutu failed to usher in policies and programs to educate the masses of his people and

    improve their lot. )ather, in +eopoldian fashion, 5obutu siphoned the riches of the $ongo to Europe, and the

    6nited 'tates, where he hid them for his personal use in European and American ban#s and real estate. 1&(

    reoccupied with personal greed, and lac#ing a positive vision for his mineral rich nation, 5obutu overall, failed

    to invest in the social welfare of his own people.1& /hile soldiers and civil servants remained unpaid for months,

    5obutu indulged in ecesses, and lavished the public>s money on himself, his family members, and all who were

    willing to go along with, and support his bra"en looting of the national treasury.1&

    5obutu>s stealing and waste of the $ongo>s abundant resources #new no bounds. $onsider this display of

    unconscionable ecessL when one of 5obutu>s daughters got married, a chartered plane ferried the wedding ca#e,

    estimated at more than thirteen feet, from aris to 5obutu>s estate in northern $ongo at the cost of sity-five

    thousand dollars to the nation. 1&2 o maintain his illegitimate and corruption riddled rule, 5obutu #illed and

    imprisoned opponents with impunity, and silenced any opposition to his despotism.1&3 'afely in power with the

    1&&'ee 'wain, )egime $ollapsing, supra note G3.

    1&('ee idpoignantly observing ?A 0rench government minister famously called resident 5obutu 'ese'e#o of Daire Hnow renamed 8emocratic )epublic of the $ongo>a wal#ing ban# account in a leopard-s#in cap.> Itis an apt description of an African leader who plundered the wealth of his country so much that he has been hailedas the inventor of #leptocracy, or government by theft...he plundered the state>s coffers, imprisoned his opponents,built a palace in the %ungle and bought chateau and villas in Europe.@.

    1&'ee id.

    1&'ee, e.g., :esh =estin, -od and Man in 7aire, 0

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    assistance and blessing of the 6nited 'tates,1&G5obutu became incredibly arrogant and self-serving.1& o crown

    his arrogance, and underscore his lac# of vision for his country, 5obutu renamed the $ongo )epublic in 131 to

    JDaire,> a term that was a Belgian corruption of the $ongolese name for the $ongo river. 1(C 5obutu also renamed

    one of the largest la#es in $ongo after himself. 1(1 ragically, while 5obutu was indulging his ego, robbing his

    country blind, and etravagantly spending on himself and his family, his country men and women were wallowing

    in utter misery and poverty,1(&and the infant mortality rate was s#yroc#eting because of a virtually noneistent

    health care system.1((

    /hile 5obutu was busy ruining and impoverishing his mineral rich nation through unbridled corruption

    and looting, Jleaders> in smaller countries such as the $entral African )epublic, 5alawi, E9uatorial ;uinea,

    ;abon, ;uinea, 6ganda, ogo, and +iberia continued the regrettable and regressive trend. In the $entral African

    )epublic, despot 7ean Bedel Bo#assa, who came to power through a military coup in 8ecember 12,1(

    epropriated the public>s money with consistent fre9uency for his personal benefit at the epense of his

    horrorR As he recoiled from a pile of massacred bodies during a rebellion in southern Daire.@ .

    1&G'ee ac#er, In the 0ootsteps of 5r. =urt", supra note 1&, at 33 emphasi"ing that the 6.'. installed5obutu in power, and then ?prolonged 5obutu>s rule by providing more than Q(CC million in weapons and Q1CCmillion in military training.@.

    1&'ee =estin, ;od and 5an in Daire, supra note 1&, at 1CC.

    1(C'ee :ochschild, supra note at observing ?$uriously, it was a ortuguese corruption of this word

    Hthe word referred to is J!"ere> the local name given to the $ongo river by the inhabitants along its ban#s-according to the author, J!"ere> means ?the river that swallows all rivers@, Daire, that $ongo dictator 5obutu'ese 'e#o pic#ed when he renamed his country in 131.@

    1(1'ee id.at (Cobserving that 5obutu changed the name of the la#e to +a#e 5obutu 'ese 'e#o.

    1(&'ee =estin, ;od and 5an in Daire, supra note 1& describing the utter hopelessness of the average$ongolese, then #nown as Daire, including low ran#ing military and police officers, the writer commented ?Is itthen any wonder that a soldier will stop you at a roadbloc# and say ?I haven>t eaten today.@ :e really hasn>t eaten.!or has the traffic cop enough to feed his family nor the ta official who ta#es his payment in cash enough to buymedicines for his #id. It is the Dairean in the street who is doubly the victim here first, because theft higher up#eeps him close to starvation second, because it forces him to become a thief as well.@.

    1(('ee id ?he nation has such useful assets as half the world>s cobalt and a 9uarter of its industrialdiamondsHDaire leads in production of both, plus untold reserves of gold, oil, copper and uranium. %ut all this isscant help to the villa'e children ho die of illnesses like measles 1ecause no one seems a1le to come up iththe F@cent@a@dose inoculations needed to save them...As many as one child in two dies here before the age of asa result of common illnesses made lethal by a diet based on manioc, a soapy tuber as lac#ing in nutrition as it is intaste.@emphasis added.

    1('ee, e.g., he $olumbia Encyclopedia, at 1C.

    &

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    impoverished sub%ects. o satisfy his self aggrandi"ement, Bo#assa declared himself emperor. 1( 8uring his

    coronation in 133, which he modeled after that of 0rance>s emperor !apoleon Bonaparte, Bo#assa reportedly

    spent about thirty million 6' dollars-approimately twenty percent of his impoverished country>s gross national

    product.1(2 /hile Bo#assa spent lavishly on himself, and indulged his ecesses, which included sitting on an eagle

    shaped throne,1(3 his sub%ects lac#ed the most basic necessities of modern living. o ensure his depraved rule,

    Bo#assa became increasingly diabolical, going as far as #illing over a hundred school children in one act of

    showing off the etent of his power.1(G o crown his arrogance and sense of self-importance the murderous tyrant

    compared himself to $hrist.1(

    In 5alawi :astings =amu"u Banda who had struggled to overcome his humble bac#ground, 1Cby earning

    a medical degree from a notable American medical college, 11helped his country gain independence. Banda went

    on to become the first president of an independent 5alawi. 'oon after assuming the presidency Banda apparently

    forgot how impoverished his small landloc#ed country was.1& 'eemingly oblivious to the serious infrastructural

    1('ee, e.g., %ush #ele'raph, supra note 11&.

    1(2'ee id ?Bo#assa>s coronation ceremony as ?Emperor@ in 133 cost Q(C million, a fifth of hiscountry>s revenues, and was attended by (, CC foreign guests.@9uotation on as Emperor in the original.

    1(3'ee id?:ighlights Hof Bo#assa>s coronation included an eagle-shaped throne. A crown containing&,CCC diamonds was worth an estimated Q million.@.

    1(G'ee A#a, :uman )ights in Africa, supra note (, at (G3?Bo#assa brutally murdered over 1CCschoolchildren for the ?political offenses@ of defying his orders and mouthing ?8eath to the Emperor.@?9uotationin the original.

    1('ee Bush elegraph, supra note 11&.

    1C'ee $hris 5c;real, #he Elite #ree of 2noled'e 2amuBu Academy the Eton of Africa as,ounded 1y the (eader )ho *elped ,ree *is Country from Colonial Rule. %ut it Offers a Classical En'lishEducation and the /tudents3 "ative #on'ue is ,or1idden, :E ;6A)8IA! +ondon, 7une &G, 1(, g. &hereinafter, 5c;eal, Elite ree of =nowledgeobserving that =amu"u Banda ?left at an early age to wor# thegold mines of 'outh Africa.@.

    11'ee =eller, supra note noting that 8r. Banda earned a medical degree from 5eharry 5edical$ollege in ennessee.

    1&'ee id observing that 5alawi is a land-loc#ed country ?whose .3 million people Has of 1 areamong the poorest in the world.@.

    &

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    needs of his country, and perhaps believing that he was indispensable to 5alawi, Banda proclaimed himself

    president for life, and built a personality cult around himself. 1( :e ensured that his face appeared on ban#notes

    and coins, and on the walls of public offices. 1 o crown his arrogant and selfish belief in his indispensability to

    5alawi, Banda consolidated most of government power into his own hands by assuming the positions, of

    5inister of Agriculture, 0oreign Affairs, 7ustice and ublic /or#s, and the rector of the 6niversity of 5alawi,

    among other positions.1 $ontinuing the obsession with himself, Banda proclaimed himself the $on9ueror. 12 he

    title would perhaps have been appropriate if he had chosen the best men and women to help him manage his

    impoverished nation, and actually come up with effective policies and the necessary budgets to educate his vastly

    under-educated people, and improve the crumbling or noneistent infrastructures. )ather, Banda>s obsession with

    his own self-importance and monopoli"ation of the top government positions was only the beginning.

    'hamelessly professing moral purity, while simultaneously maintaining a mistress whose first name was $ecilia,

    Banda banned in the 12Cs the song J$ecilia> by 'imon and ;arfun#el, and %ailed many who dared to sing it, on

    the ground that the song was an affront to his mistress. 13 :e followed his hypocritical moral crusade by banning

    minis#irts for women and long hair on men as signs of moral decline.1G

    It would perhaps have been easier to forget Banda>s self obsession with his own importance, and his

    morali"ing double-standard as the eccentricities of an outdated despot, but for the fact that Banda totally ruined the

    hopes of the vast ma%ority of his people through his corruption. In a nation where most of the people live without

    running water or electricity due to his inept policies, resident Banda maintained five official residences, and

    1(Id.

    1'ee id ?:is HBanda>s face appears on coins and ban#notes, on the walls of every shop and office,and on the bright cloth worn by the ululating women who are bused out to greet him at every staged stop on hisitinerary.@.

    1'ee idin addition to the mentioned positions, Banda was ?the trustee of a state monopoly thatcontrols tobacco farms, factories, oil, ban#ing and insurance, ...and the dominant figure in the local resbyterian

    $hurch of 'cotland.@.

    12'ee %ush #ele'raph, supra note 11&.

    13'ee id.

    1G'ee =eller, supra note .

    &2

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    In the very small,13but highly impoverished nation of E9uatorial ;uinea, 1G0rancisco 5acias !guema

    ushered in a very vicious and corrupt regime soon after independence in 12G from 'pain. 1s 7oseph 'talin and $ambodia>s ol ot, !guema reportedly #illed up to eighty thousand of his

    fellow citi"ens, mostly intellectuals and all whom he deemed a threat to his murderous rule. 12& !ot content with

    #illing ordinary citi"ens, !guema carried his murderous mission to his cabinet ministers, and senior civil servants,

    most of whom he had #illed. 12( 8eath s9uads reportedly roamed the countryside #illing and raping all those

    opposed or perceived to be opposed to !guema. 12

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    demanded godli#e respect by ordering the hanging of his picture beside every altar of every church and the singing

    of his name at every service.12 0urther, !guema ushered in corruption of the highest order. :e reportedly

    literally hid bags of the public>s money in a bamboo hut net to his house. 122 hrough his massive theft of public

    money !guema further impoverished his already poor nation, failed to ma#e conditions conducive for developing

    his country, and led it to the brin# of penury. 123 he etent of !guema>s wanton and callous rule was such that he

    was toppled in a bloody military coup and summarily eecuted by his own nephew, +t. $olonel eodoro s 5acias !guema stashed the nationaltreasury in a bamboo hut net to his house.@.

    123'ee $helala, ;rowing ains in E9uatorial ;uinea, supra note 1G ?8uring his H!guema>s reignmost foreign industries left the country, which resulted in drastically diminished returns from the three maineportsL cocoa, timber and coffee.@.

    12G'ee Engel, Brute /atch, supra note 13 ?resident eodor basago too# power bymurdering his uncle, resident !guema, himself a world-class mass murderer, in 13.@.

    12'ee $helala, ;rowing ains in E9uatorial ;uinea, supra note 1G.

    13C'ee id.

    131Id.

    13&'ee id ?:ealth conditions in E9uatorial ;uinea are generally poor, despite a bountiful nature,especially on the island of Bio#o. In 1C the infant mortality rate was estimated at 1& per thousand life births, amodest improvement over the 1GC estimate of 1C.@. 'ee also Engel, Brute /atch, supra note 13observingthat ?at last count HE9uatorial ;uinea has five doctors,@ in the entire country.

    13('ee #o'o A -eneral )ell $u' In, :E E$

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    0our years later, Eyadema too# over power.13 /ith the loyal support of the military, most of whose commanders

    he chose through nepotism and favoritism, 13 and the support of 0rance, 132 Eyadema has earned the dubious

    distinction of being ?the longest-serving African president still in office.@133 hrough intimidation and murder

    Eyadema has maintained his long hold on power. 13G Although forced in 11 by western creditors to ac9uiesce to

    political pluralism, 13resident Eyadema has continued to rule ogo through intimidation and the inflation of the

    electoral rolls to his favor.1GC 8etermined to maintain power at all costs, Eyadema has turned ogo into his

    personal fiefdom-dishing out the best government %obs and opportunities to members of his minority ethnic group-

    the =abye, and overwhelmingly staffing the military with his cronies,1G1 with hardly any consideration for

    meritocracy, and the welfare of the entire ogolese people.

    he same corruption and determination to hold on to power at all costs to the utter detriment of the

    citi"ens goes on in war torn +iberia, ;abon, and Dimbabwe, among other small to medium si"ed African countries.

    +iberia is an eample of rampant corruption resulting in the unimaginable misery of the populace. resident

    /illiam olbert, 7r. embodied the worst of nepotism and favoritism by employing his relatives without regard for

    13'ee id.

    13Id.

    132'ee "ot #oo #o'ether in #o'o, :E E$

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    9ualifications and putting them in high government positions. olbert installed one of his brothers as the president

    of the +iberian 'enate,1G&and another as the 0inance 5inister. 1G(:e installed his sister 5ayor of Bedel $ity and

    two of his daughters as residential hysician and 8eputy 5inister of Education, respectively. 1G:e appointed his

    son Ambassador at +arge and various sons-in-law and brothers-in-law to some of the highest positions in the

    country.1G

    Along came 5aster 'ergeant 'amuel =anyon 8oe who assassinated olbert in a bloody coup de tat and

    promised to ma#e things better for the average +iberian. 1G2 Alas, the endless brea#ing of promises in Africa.

    Instead of improving conditions for +iberians, 8oe who later self promoted himself from 5aster-'ergeant to what

    he termed $ommander-;eneral, turned +iberia into his private estate through blatant misrule. 1G3!ot surprisingly,

    8oe>s misrule fueled a rebellion against his regime. 'pearheading the rebellion against 8oe were his former

    minister, $harles aylor, and rebel leaderPwarlord Fommie 7ohnson. 1GGhe ensuing rebellion culminated in a civil

    war #nown for its etreme violence and cruelty.1G

    After the capture and brutal murder of 8oe by Fommie 7ohnson, 1C$harles aylor somehow rose up to the

    head of the pac#, and became the resident of +iberia in 13. 11 :owever, instead of tac#ling the infrastructural

    and other problems of +iberia, aylor continued the saga of misery and despair of +iberia. In echange for the

    1G&'ee, e.g., 7ide A%ani, AA-M: ,our ?ears After: %eteen 2udirat A1iola and /ani A1acha,KA!;6A)8 !igeria, 7une 3, &CC&.

    1G('ee id.

    1GId.

    1GIdnoting ?:is four sons-in-law were 8eputy 5inister of ublic /or#s, $ommissioner forImmigration, 5inister of 8efence and Board 5ember of Air +iberia, respectively.

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    profits from ill-gotten diamonds, aylor championed the cause of an insidious rebel group in neighboring 'ierra

    +eone #nown for its +eopoldian practice of cutting off the limbs of ordinary citi"ens who failed to profess their

    undivided loyalty to the rebels.1& In addition to this sadistic support, aylor continues to rule +iberia through

    intimidation, torture, and murder.1( 5eanwhile, the case of ;abon is another eample of corruption and

    incompetent leadership run amo#. ?6pon formal independence from 0rance in 12C, ;abon, the si"e of

    $onnecticut, possessed the greatest economic potential in blac# Africa. /ith a small population and rich in oil

    and other resources, ;abon appeared destined for prosperity.@1 Fet ;abon>s enormous potential has been

    s9uandered under the incompetent and tyrannical rule of resident

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    most able leaders,@&C5ugabe became the leader of Dimbabwe. 5ugabe inherited a reasonably prosperous country,

    by African standards, with a blac# middle class ready to assume the mantle of leadership across the political

    landscape.&CIn the early years of his administration resident 5ugabe wor#ed to improve the conditions of his

    people by, among others, epanding access to education.&C2 But soon thereafter, his lust for power and

    determination to crush all credible oppositions got the better of him. Barely three years after independence,

    5ugabe ordered a brutal assault against the !debele, an ethnic group loyal to his main political rival, 7oshua

    !#omo.&C3 erhaps emboldened by the ability of his security operatives to crush those hostile to his regime, as

    eemplified by the brutality against the !debele, 5ugabe began to tarnish his earlier accomplishments. :e ignored

    growing corruption within his government and rewarded his cronies handsomely. &CGhe tragic result was the utter

    and complete reversal of fortune of a once vibrant and highly promising nation. By 1, 5ugabe>s misrule had

    reportedly resulted in an eye-popping inflation rate of about 3CM, while unemployment reached a staggering CM

    in the year &CCC.&C

    Intent on maintaining power at all costs, after reali"ing the precipitous drop in his government>s support

    among the blac# ma%ority, 5ugabe desperately sought to divert attention from the ban#ruptcy of his polices by

    supporting a constitutional amendment giving him epansive powers to sei"e lands belonging to white citi"ens

    without the payment of compensation.&1C /hen that amendment failed, 5ugabe came up with a facade to get ride

    of those who had voted against the amendment. &11 5ugabe and his government engaged and continue to engage in

    &C'ee )achel +. 'warns, #he )orld: Poer in %lack and )hite Mu'a1e3s Real ,oes Aren3t theOnes *e $enounces, :E !E/ F

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    waging an ill-advised, unlawful, and race-baiting land reform campaign against the few white farmers who had,

    either willingly or unwillingly, been the beneficiaries of colonial Britain>s mischievous and unconscionable land-

    grab of native lands. Even though he had lost the attempted constitutional amendment to confiscate lands without

    compensation, 5ugabe failed to pursue other viable legal alternatives to the land reform issue. Although Britain

    had robbed natives of their lands during its colonial occupation, and shamelessly transferred ownership of these

    lands to whites, thus ma#ing land reform mandatory and %ustified under an independent Dimbabwe, &1& 5ugabe

    failed to pursue legal avenues after the aborted constitutional amendment, such as initiating an amendment that

    would, for eample, allow the government to condemn lands through the power of eminent domain with a

    conse9uent payment for reasonable value, and resale of same to blac#s at affordable rates. )ather, 5ugabe chose

    to support lawless ta#eover of lands, which has resulted in the #illing of hundreds of Dimbabweans, mostly blac#s

    opposed to 5ugabe>s irrational policies, at the hands of 5ugabe>s thugs &1( and its near ostracism within the

    international community.&1

    Also, during the 5arch &CC& presidential election, 5ugabe hi%ac#ed the electioneering process by

    encouraging violence and murder against members and supporters of his main presidential rival, 5organ

    svangirai. &1he result of the &CC& presidential election was the alleged reelection of the aging 5ugabe under

    conditions so atrocious, and so lac#ing in democratic participation that it could not be deemed fair. &12 he

    tempestuous decline of the Dimbabwean economy, and the free wheeling corruption by resident 5ugabe>s

    government, appears to leave the fate of this young and once vibrant country uncertain.

    he crowning eample of governmental corruption and betrayal of the hopes of the citi"enry in Africa

    &1&'ee generally id. Also, see generally :ochschild, supra note .

    &1('ee 'warns, 5ugabe>s )eal 0oes, supra note &C.

    &1'ee, e.g., ,rom *ero to #hu', +

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    appears to be !igeria, due to its si"e,&13 and its abundance of mineral resources.&1G !igeria gained its

    independence from Britain on s $ongress ?!$@, led by Ahmadu Bello, and the !ational

    $onvention of !igerian $iti"ens ?!$!$@, led by !namdi A"i#iwe, Abuba#ar afewa Balewa, a northerner,

    was selected as the first rime 5inister, while !namdi A"i#iwe, an easterner, was selected as the ;overnor-

    ;eneral.&&C /hen in 12( !igeria became a republic, A"i#iwe was made the first president of the new nation. &&1

    Barely three years after independence political wrangling among and between the different political parties built

    around ethnic loyalties, severely tested the stability of the young nation. &&&

    he tensions among the parties and the politicians perhaps sowed the seeds for the first military coup in

    7anuary 122, led by Ibo army officers, which resulted in the deaths of the rime 5inister, Balewa the !orthern

    remier Ahmadu Bello and the /estern remier '.I. A#intola.&&( An Ibo 5a%or-;eneral, 7ohnson .6. Aguiyi-

    Ironsi became military dictator.&&An e9ually bloody and brutal counter military coup si months later-7uly 122

    by :ausa army officers led to the death of Aguiyi-Ironsi, the massacre of the Ibos in the northern part of !igeria,

    &13!igeria is the most populous country in Africa, with a 1 estimated population of more than 1C1million people. 'ee $olumbia Encyclopedia, supra note 11(, at &C13.

    &1G'ee, e.g., Anthony ;oldman and /illiam /allis, /urvey@"i'eria: #readin' )ater as the,rustrations Rise ith Politicians Under Pressure to /pend #heir )ay Out of #rou1le %efore Electioneerin'

    #akes Over, 0I!A!$IA+ I5E' +ondon, 'urvey 'ection-!igeria, at pg.1 highlighting !igeria>s status asAfrica>s leading oil producer, 5arch (C, &CC1 Eli"abeth aylor, A "ation on the %rink 5ournalist 2arl Maier$iscusses *is %ook A1out the #rou1led )est African Country of "i'eria , $:I$A;< )IB6!E, 'unday,'eptember &, &CCC, $hicagoland 0inal Edition, at $( hereinafter, aylor, A !ation on the Brin#noting that!igeria is ?a country with abundant resources@ 8avid s sith largestproducer of crude, with an output of about two million barrels a day.@,

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    and the placement of +t. $ol. Fa#ubu ;owon as military dictator. && According to one scholarly estimate, about

    thirty-thousand Ibos were massacred in the aftermath of the bloody counter-military coup. &&2 he culmination of

    the initial coup, counter coup, and massacres of the Ibos was the brutal and ecessively violent !igerian-Biafran

    civil war, which reputedly ran#s as the most brutal civil war of the twentieth century. &&3

    0rom 122 through 13 Fa#ubu ;owon ruled !igeria, until he was overthrown in a bloodless coup by

    ;en. 5urtala 5ohamed and a group of officers which promised a return to civilian rule. &&G Barely a year into his

    administration, 5ohamed was assassinated in a bloody coup. &&5ohamed>s deputy, ;en. s indecisiveness soon provided the impetus to divisive and

    corrupt politicians in the country, particularly within his party, to foment ethnic conflicts and destabili"e the new

    democracy.&(( 8espite the new government>s slogan of attac#ing corruption, political corruption erupted with

    unbridled ferocity.&( )egrettably, leading the pac# of corrupt officialdom was one of resident 'hagari>s closest

    &&'ee id.

    &&2'ee A#a, olicy of Ethnic )econciliation, supra note 1, at (((.

    &&3'ee id, citing A.:.5 =ir#-;reene, $risis and $onflict in !igeriaL A 8ocumentary 'ourceboo# 122-

    12, Kolume 1L 7anuary 122-7uly 123, p. ((( 131.

    &&G'ee he $olumbia Encyclopedia, supra note 11(, at &C1G.

    &&'ee id.

    &(C'ee id. 'ee also, Under "e Mana'ement, :E E$

    &(1'ee Under "e Mana'ement, supra note &(C.

    &(&'ee, e.g., "i'eria /econd Chance for $emocracy, !E/'/EE=, 6nited 'tates Edition, 5arch (C,1G1, at pg. & hereinafter, 'econd $hance for 8emocracy?'hagari inherited a relatively stable political andeconomic situation...by the time civilian government was restored, !igeria was snapping out of a deep recession,mostly than#s to oil production. 'hagari was given as good a start as he could epect.@.

    &(('ee id.

    &('ee id noting that corruption was fast on the rise, and had began undermining the confidence offoreign investors in the country, thereby wea#ening the economy.

    (3

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    associates, and brother-in-law, ransportation 5inister 6maru 8i##o, who allegedly stole up to a billion dollars

    from the national treasury.&( /hile officials under 'hagari were preoccupied with robbing the country blind,

    massive unemployment and staggering inflation were ma#ing the lives of the average !igerian unbearable.&(2 At

    the same time, the rate of crime was going through the roof. &(3 Adding to the crippling social and economic

    problems was the soaring foreign debt which had climbed to Q&C billion by 7anuary 1G. &(G !otwithstanding the

    woes facing the country, as a result of 'hagari>s inept rule, government officials continued to gorge on +ear%ets

    and 5ercedes limousines, in apparent indifference to the misery of the average citi"en. &( 'eeing an ecuse for a

    military comebac#, the military overthrew the 'hagari administration on !ew Fear>s eve, 8ecember (1, 1G( in a

    near bloodless coup, barely four months after 'hagari had won reelection to a second term. &C At the head of the

    military %unta which overthrew resident 'hagari was a &-year-old 5a%or.

    ;en., 5ohammed Buhari.&1 he suffering citi"ens resigned themselves to the new leadership, which

    promised a vigorous fight against corruption, and the restoration of basic amenities, such as drin#ing water and

    &('ee, e.g., )obert B. $ullen and ony $lipton, %ritain the Car'o@Crate 2idnapin', !E/'/EE=,6nited 'tates Edition, 7uly 12, 1G, at pg. (2 observing that resident 'hagari>s close associate, and brother-in-law, 6maru 8i##o, was part of corrupt officials who ?siphoned anywhere from Q billion to Q12 billion out of thecountry,@ before 'hagari was overthrown. According to the account ?8i##o, the president>s brother-in-law,allegedly got a large share Hof the stolen loot-perhaps a billion dollars.@. 'ee also 7ohn 5oody and Alastair5atheson, #riumph of the #rou1lemaker #he Man %eyond J%ehindKMany Coups ,inally Puts *imself inPoer, I5E, 6.'. Edition, 'eptember , 1G, at pg. G hereinafter, 5oody 4 5atheson, riumph of the

    roublema#er?he 'hagari regime>s tolerance of corruption only added to the country>s woes. In 1G( alone,according to

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    electricity for all.&& :owever, perceived as heavy-handed, and largely ineffective in reviving the lumbering

    economy and wiping out endemic corruption, Buhari was overthrown by year old Army $hief of 'taff ;en.

    Ibrahim Babangida in 'eptember 1G. &( 6pon ta#ing the helm, Babangida, who allegedly had also been behind

    the overthrow of ;en. ;owon and resident 'hagari, & repealed a draconian edict promulgated by the Buhari

    regime w