The Protocol Establishing the African Court on Human and Peoples' Rights was adopted by the Organisation of African Unity on 10 June 1998 and came into effect on 15 January 2004. Only 19 States have ratified the treaty although 45 have signed it. More recently, at the AU Assembly in July 2004 a decision was taken to merge the African Court on Human and Peoples' Rights with the Court of Justice of the African Union. What are the implications of this merger?