2: Expression of the Freedom of Trade Union 213- Government intended to update the trade unions card index since October 2015 162 to have an updated inventory of professional organizations for a better organization of social dialogue. The operation helped identify 717 trade unions and 12 employers’ confederations in 2018. Besides, the employers’ representation mechanisms were effective. In this regard, 7,480 staff delegates affiliated to 11 trade union federations were chosen following elections organised on 1 March and 8 April 2016 nationwide163. §3: Protection of Workers against Wrongful, Unjust, unjustified Termination and Forced Resignation 214- The information contained in the previous Report (§210-213) is still relevant. However, it should be noted that courts sitting on labour matters regularly ruled on matters of wrongful dismissal. In cases, for example, where workers formerly linked to an enterprise by an openended contract, refused following the change of the form of the enterprise to a private limited company, to sign fixed term contracts proposed to them by the employer, the Court of Appeal of the North holden at Garoua held that in fact it was a dismissal164, considering that substantial amendments to employment contracts should be negotiated and during the negotiations, common ground should be reached by the parties by mutual agreement 165. 215- The non-compliance with procedural formalities in matters of dismissal was also sanctioned by the courts. The Court of Appeal of the Adamawa holden at Ngaoundere upheld a judgment of the trial court that had considered that a letter notifying the worker that he was no longer a staff of the company was a letter of dismissal served on him in violation of the provisions of section 34166 of the Labour Code. Section 3: Right to Health (REC. 14 to 18) 216- During the reporting period the strategic framework for the health sector was strengthened. Government took measures to improve on the availability of and accessibility to healthcare services including sexual and reproductive health. The control of diseases was also a priority. §1: Strategic Framework 217- Progress was made concerning the strategic framework as a new Health Sector Strategy (HSS) (2016-2027) was validated on 27 June 2017. The National Health Development Plan 162 36 trade unions were formed in 2013, 12 in 2014, and 27 in 2015. Order No. 2016/101/MINTSS/SG of 11 July 2016 to lay down the national classification of the confederation of trade unions. 164 Court of Appeal of the North (Garoua), Judgment No. 6/SOC of 1 September 2016 in the matter between La Pharmacie de Garoua SARL and Moussa Tanko; Judgment No. 7/SOC of 1 September 2016 in the matter between La Pharmacie de Garoua SARL and Djayou Oumarou; Judgment No. 9/SOC of 1 September 2016 in the matter between La Pharmacie de Garoua sarl and Djikam Rikiatou. 165 Court of Appeal of the North (Garoua), Judgment No. 6/SOC of 1 September 2016 in the matter between La Pharmacie de Garoua SARL and Moussa Tanko. 166 Judgment No. 21/SOC of 6 July 2015 delivered by the Court of Appeal of the Adamawa in the matter between the Secrétariat à l’Education de l’Eglise Evangélique et Luthérienne du Cameroun (SEDUC-EELC) and Adamou Silas. Court of Appeal Judgment upholding Judgment No. 9/SOC of 23 April 2013 delivered by the High Court of Vina holden at Ngaoundere. The employer was convicted and ordered to pay Plaintiff damages for wrongful termination and issue him a labour certificate. See also Judgment No. 22/SOC of 6 July 2015 by the same Court of Appeal in the matter between Yakoubou Paul and Secrétariat à l’Education de l’Eglise Evangélique et Luthérienne du Cameroun (SEDUC-EELC). 163 44