that "no one can be deprived of it, unless a legally established public necessity demands it, under the condition of a just and prior indemnity”. Requisitions based on procedures for expropriation in the public interest are among the most common reasons for an individual to be deprived of their property. 155. Pursuant to Act No. 172-AN of 10 October 1991 on expropriations in the public interest, the Government may, under the condition of a just indemnity, expropriate land in the public interest. 156. Expropriation is conducted by means of a regulatory text (decree, order) following several procedures to clearly establish the materiality of this public interest and the need to expropriate and after other means such as sale or exchange have been exhausted. 157. The law guarantees individuals the possibility to bring their expropriation case before the Administrative Court if the procedure is flawed in any way. The Court may order that the expropriation act be repealed. 2. Right to the enjoyment of fair and favourable conditions of work Article 15 Every individual shall have the right to work under equitable and satisfactory conditions, and shall receive equal pay for equal work. 158. Though these provisions of the Charter are not included in the Constitution of Djibouti, they are guaranteed by the State in view of their social nature and the fact that it “owes” each citizen the right to work and social protection. 159. To ensure the realization of this right, the State through the Ministry of Labour and Civil Service in particular, is implementing specific policies as well as other measures to promote recruitment in the civil service, private sector and parastatals. 160. Based on the third household survey for social indicators (EDAM3-IS) in 2012, the State is the first employer of Djibouti with 41.3% of the active population working in the civil service. A competitive recruitment process is organized for access to civil service employment. In addition to the competitive recruitment process, the State also recruits based on applications and professional review where required. 161. Economic difficulties as a result of the civil war and budget restrictions initiated under the supervision of the IMF led to a rapid decline throughout the ‘90s in the observance and protection of the right to fair and satisfactory conditions of work in the civil service. 162. To remedy this situation, Djibouti progressively initiated several measures to restore basic conditions of work for civil servants and contract-based workers such as the payment of salary arrears and the resumption of career advancements in the early 2000s. The State has since been paying salaries on a 33

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