From Accord to Action: Evaluating Nepal's Transitional Justice Mechanism Over Two Decades of Waiting

Author: Deeya Nepal

June 19, 2026

~“Justice delayed is Justice denied"

[Image credit: Kalea Morgan on Unsplash via Online Khabar]

Introduction 

Nepal went through ten years of Maoist Insurgency from 1996 to 2006. The ceasefire was achieved through signing a Comprehensive Peace Accord on 21 November 2006. 10 years of conflict left over 13,000 people dead and 1,300 missing (OHCHR 2012). The Comprehensive Peace Accord was signed to restore peace in the society and rehabilitate and restore people victimized and displaced by the war. This is how the concept of transitional justice emerged during the post-war period. 

During the pre-conflict era, the Communist Party of Nepal (CPN (Maoist)) submitted a list of demands, known as the 40 point demands, on February 4, 1996 stating that severe poverty, unemployment and the verge of bankruptcy, economic inequalities, caste and ethnic discrimination, and other severe issues that the nation was facing required urgent action by the government, and that if there was no positive indication of action towards them from the government by 17 February 1996, the CPN (Maoist) would start an armed struggle against them (Martin Chautari 2021). One week later, they launched an organized, armed insurgency against the state, which lasted for ten years. During the ensuing years, the Maoist rebels gained significant control over rural areas, while the government retained control of the main cities and towns. Later years saw increasing and effective insurgent attacks on police and military personnel (Asia Foundation 2018).

Following the royal massacre of Nepal in June 2001, political instability and public dissatisfaction with monarchical rule intensified. Growing pro-democracy movements and nationwide protests against the monarchy ultimately compelled King Gyanendra to reinstate Parliament, leading to the signing of the Comprehensive Peace Accord between the Government of Nepal and the CPN (Maoist).

The conflict severely affected many lives and produced a diverse group of victims, including the disappeared and their families, as well as victims of unlawful killings, torture, arbitrary arrest, and sexual violence. Vulnerable groups like women, children and people from other marginalized groups became more vulnerable after victimization. Despite decades of ceasefire having passed, many victims continue to face challenges in access to justice, rehabilitation, restoration, and truth, raising concerns about the implementation of transitional justice being promised to them. 

The notion of transitional justice was discussed in 2024 in a report titled "The rule of law and Transitional Justice in Conflict and Post-conflict Societies" by the United Nations (UN), stating it as a process and mechanism associated with a society’s attempts to come to terms with a legacy of large-scale past abuses, in order to ensure accountability, serve justice and achieve reconciliation (United Nation 2004). It further states that the justice may include both judicial and non-judicial mechanisms, with differing levels of international involvement, reform, vetting, and dismissals, or a combination thereof. Transitional justice is not a distinct or ‘soft’ form of justice, but rather a set of approaches to achieving justice, broadly understood, in order to address legitimate grievances (US 2016). If applied in a manner consistent with the guiding principles - which include being comprehensive, transparent, independent and impartial, consultative and participatory, and gender-inclusive - it has the potential to mitigate the risk of further violence, promote civil security, and strengthen the rule of law. Therefore, ensuring transitional justice through statutes is not enough for justice to be served; it needs to be applied in a manner consistent with the guiding principles.  

Legal Instruments Ensuring Victims’ Rights 

As a non-judicial mechanism towards transitional justice, legal instruments play a significant role in ensuring the rights of victims of conflict. These instruments consist of binding agreements, the Constitution, and treaty bodies, which have ensured the right to remedy for the victims of armed conflict in Nepal. 

1. Comprehensive Peace Accord

The Comprehensive Peace Accord (CPA) serves as the foundational framework for serving transitional justice following the conflict. It recognized the need to address human rights violations and victims' rights, and promote dispute settlement and implementation mechanisms. Through the accord, the parties agreed to form a National Peace and Rehabilitation Commission (CPA 2006) to establish peace and rehabilitate people victimized and displaced by war and a High-level Truth and Reconciliation Commission (CPA 2006) to investigate the truth and to create an environment for reconciliation in the society. The parties further committed to the restoration of the people back to society who have been displaced due to armed conflict and to take responsibility in individual and collective manners for normalizing relations and reconciliation. More specifically, the CPA has ensured the rights of the victims of conflict and torture and the families of the disappeared to obtain justice (CPA 2006). 

2. Enforced Disappearances Enquiry, Truth and Reconciliation Commission Act, 2014.  

With the commitment to create an environment for reconciliation and to investigate the facts about those involved in violation of human rights and crimes against humanity during the course of the armed conflict, and to provide relief to the families of the victims who were subjected to disappearance, the Enforced Disappearances Enquiry, Truth and Reconciliation Commission Act was formed. This Act also established the Enforced Disappearances Enquiry Commission and Truth and Reconciliation Commission for the investigation of the truth regarding the violation of human rights during the conflict. 

The Enforced Disappearances Enquiry Commission investigates matters relating to the enforced disappearances, and the Truth and Reconciliation Commission investigates matters relating to other incidents of violations of human rights. 

Apart from investigation, the Commission aims to ascertain victims and perpetrators, bring out reconciliation between the perpetrators and victims, recommend repatriation to be provided to victims or their families, and recommend to the attorney general, along with the report of investigation, whether to file a criminal proceeding against such individuals or not. The Commission formed through this Act consists of a supreme body to regulate end-to-end proceedings to ensure justice among victims of conflict. 

For repatriation of the victims, the Commission makes recommendations to the Government of Nepal to provide compensation to the victim, to make restitution or to rehabilitate the victim through free education and medical treatment, skill-oriented training, loan facilities without interest, arrangement for settlement, facility of employment and other facilities. Further, it has been stated that victims shall not be deprived of these facilities required for repatriation even if victims have been compensated by the perpetrator or the perpetrator has been recommended for amnesty or if any perpetrator has not been found. 

Even though the Enforced Disappearances Enquiry, Truth and Reconciliation Commission Act has tried to address all the aspects required to ensure justice is served, the implementation of the Act in reality raises questions among the victims concerning the justice they deserve. For example, Nepal’s Supreme Court has repeatedly ordered the government to investigate gross violations of human rights and international humanitarian law during the conflict from 1996 to 2006, and to conduct a meaningful, effective transitional justice process to establish the truth and provide justice for thousands of cases of serious abuses. In 2020, the CIEDP published a list of 2,506 people allegedly forcibly disappeared, but it has failed to determine what happened to a single victim, and nobody has been held accountable. 

3. Interim Constitution of Nepal, 2007

The Interim Constitution of Nepal was the outcome of the people's revolution and the movement and hunger to establish democracy in the country. Many people have lost their lives to establish democracy in Nepal. The Constitution was formed through collaboration between political parties and the CPN (Maoist).Therefore, this constitution holds a responsibility to address the victims of the conflict and restore peace in the country.  

Under Article 33 of the Interim Constitution of Nepal 2007, it has been stated that it shall be the responsibility of the state to make arrangements for appropriate relief, recognition and rehabilitation for the families of victims and to form a high-level Truth and Reconciliation Commission to investigate the facts about those persons involved in serious violations of human rights and crimes against humanity committed during the course of the conflict and to create an atmosphere of reconciliation in the society. 

4. International Law 

Nepal - being a party to the United Nations - is committed to the UDHR and its principles. Article 8 of UDHR states that “Everyone has the right to an effective remedy by the competent national tribunals for acts violating the fundamental rights granted them by the constitution or by law” (UN 1948). 

Nepal being party to ICCPR should also act in strict adherence to Article 2 which states recognition of rights in covenant, by adopting law to give effect to it, Article 6 of the covenant states that every human being has the inherent right to life, protected by law and no one shall be deprived of it, Article 9 states on right of everyone to liberty and security of a person (UN 1966). These provisions of ICCPR came into force directly concerning the armed conflict. 

In furtherance of international law, Article 14 of CAT states that each state party shall ensure in its legal system that the victim of an act of torture obtains redress and has an enforceable right to fair and adequate compensation, including full rehabilitation as possible and in case of death of the victim, their dependents shall be entitled to compensation (UN 1984). Nepal has ratified CAT and is bound by the obligations set out by it. 

The UN has passed resolutions on the Basic Principles and Guidelines on Right to Remedy and Reparation for Victims of Gross Violations of International Human Rights Law and Serious Violations of International Humanitarian Law (UNGA 2005).  Principle 9 of the statute is about the reparation for harm suffered through adequate, effective and prompt reparation to promote justice by redressing gross violations of IHRL and IHL. Similarly, Principle 10 states that access to relevant information concerning violations and the reparation mechanism under which states should develop means of informing the victims about the available legal, medical, psychological, and social services. 

Nepal has ratified almost all core human rights treaties. International communities have always raised concerns regarding Nepal’s implementation of these treaties to ensure transitional justice. This was among the core recommendations of Nepal's third cycle of UPR. The Supreme Court of Nepal has stated in the case of Rajendra Dhakal V. GON, Rajendra Ghimire V. Office of the Prime Minister and Others, Rajaram Dhakal V. Office of Prime Ministers and Others, Madhav Kumar Basnet V. Government of Nepal, the Supreme Court of Nepal has emphasized the state's obligation to ensure that transitional justice mechanisms comply with international law and established international standards. Nepal, being a party to the UN, is also bound to act in accordance with these basic principles and guidelines. 

Present Status of Transitional Justice in Nepal 

Eight years after the signing of the Accord and forming the Constitution,  CIEPD and TRC were formed through enacting the Enforced Disappearances Enquiry, Truth and Reconciliation Commission Act, 2014. The Commission was initially formed for two years, however it has been functioning until today, where it’s already been two decades since the signing of the Comprehensive Peace Accord and twelve years since the formation of the Commission. The state has not yet fulfilled its responsibility towards the victims of the conflict. 

In a report published by TRC, a total of 63,718 complaints have been filed in the Commission concerning core human rights violations. The diagram of the data is shown in Figure 1. 

Figure 1: Complaints hearing status 

Among the 63,718 complaints being filed, only 3,687 preliminary investigations have started. Similarly, among these complaints, the maximum number of these was seen concerning serious human rights violations, which include homicide, kidnapping and hostage taking, grievous hurt, physical and mental torture, rape and sexual harassment, displacement, disappearance, subject not being disclosed, and others, which have been shown in Figure 2.

Figure 2: Types of Complaints being filed

Further, the current situation of conflict victims in Nepal reflects the slow and incomplete progress of the transitional justice process. Despite the establishment of formal mechanisms, many emblematic cases remain unresolved, reflecting persistent institutional delays. For instance, Lalkumari Silwan was only 25 when her husband was killed during the conflict. Two decades later, she says, “So much has changed—the war ended, governments changed, former enemies now share power—but we, the ones who lost everything, are still waiting for justice” (Kathmandu 2025 ). Further, Sapan Rana, who was tortured by the then Royal Nepal Army and lost her leg during the conflict, states, “Even now, my heart skips a beat remembering those days. It's been 20 years since the peace process began—where is our justice?”  (Kathmandu 2025). A group of conflict victims called on OHCHR to withhold its support for Nepal’s Transitional Justice Commission, where they started advocating for a reset of the THJ process- one that is transparent, inclusive, and victim-led, capable of delivering genuine justice and institutional reform (Kathmandu Post 2025). They also urged OHCHR to stand firm on international standards and Supreme Court rulings that require the transitional justice process in Nepal to be impartial, independent and inclusive.

Supreme Court Ruling on Transitional Justice 

The Supreme Court of Nepal has emerged as a significant body in ensuring transitional justice in Nepal. The Court has addressed gaps in statutory and procedural frameworks to facilitate the effective implementation of transitional justice mechanisms while safeguarding the rights of conflict victims. The court has also stated that laws are ultimately for enforcement; therefore, enforcement of the laws promulgated by the state under legislative rights is the duty of the government and its subordinate agencies. Through the following precedents, the Supreme Court has sought to keep the concept of transitional justice alive:

1. Pariman Tamang V. Government of Nepal (Pariman 2006) 

In this case, a mandamus order was issued by the court stating that the family members of the victims who were killed by the state party illegally and arbitrarily shall be provided with proper and adequate compensation for the loss and effects of such an incident to the family members of the deceased and their dependents. 

2. Rajendra Dhakal V. Nepal Government, Ministry of Home Affairs and Others (Rajendra 2059)

In this case, writ petitions were filed for the release of the petitioners, declaration of their status and legal action against those officers responsible for gross and systematic violation of human rights and for ending the state of impunity. 

In this case, the court issued an order directing the government to make a law concerning the enforced disappearance of persons and to provide relief. The court also address that, even as the international convention has not come to force till date and Nepal has also not ratified it, this convention has determined a fundamental standard concerning the obligation of the state with respect to security of disappeared persons; and also in the condition that the convention has been accepted by international community, it is expedient to accept the standards of the conventions as the standards of international law and thereby carry out activities by the states pursuant to the same. While citing Article 9 of the Treaty Act of Nepal, the court stated our legal compliance with international law and how we, as a state, are obliged to follow it. 

The court states that human rights, peace and justice are the foundation of democracy. It is, in fact, an act of paying respect to the spirit of the people’s movement to implement the provisions of the constitution that provide for a proper assessment of the loss of lives and property that occurred during the time of conflict and bring the culprit to justice and provide appropriate remedy, including repatriation to the victims.

3. Rajendra Ghumire V. the office of the Prime Minister and Others

In this case, the Supreme Court has issued a mandamus against the government of Nepal to draft a law for criminalizing the act of torture. The court also  emphasized on implementation of Nepal’s ratification of various international conventions and highlighted the importance of fulfilling the obligations arising from those instruments in accordance with international law. Further, the court stated to provide compensation to the victims of torture during the time of conflict. 

4. Rajaram Dhakal V. Office of the Prime Minister and Others (Rajaram 2060) 

In this case, the court held that Nepal, being party to the Geneva Convention and citing Article 9 of the Treaty Act, has a duty to implement treaties through domestication of the Geneva Convention, ensuring the rights of victims. Further, Nepal, being party to the convention, should respect its provisions by undertaking to enact legislation necessary to provide effective penal sanctions for persons committing or ordering to be committed any of the grave breaches of the present convention. 

5. Madhav Kumar Basnet V. Government of Nepal (Madhav 2070) 

In this case, the Supreme Court of Nepal clarified Nepal’s obligation under international standards. It states that CEDP is an important human rights convention, and even though Nepal is not party to it, as a member of the United Nations, Nepal needs to incorporate its provisions and domestic legal framework. Further, citing article 4 of  ICCPR, the court stressed the right to life as the inherent right of every person and citing CAT, the court also held on the prohibition on subjecting any person to inhuman torture. Therefore, in accordance with these established principles and norms, it is necessary that the violation of human rights and such perpetrators be subjected to criminal liability. The court also states that Nepal not being party to CEDP does not justify ignoring provisions concerning such acts. 

In furtherance of this case, the court also states that it is the responsibility of the states to create an environment for victims to have trust in the justice system, and perpetrators cannot escape liability arising from the violation of the law.While citing resolution no 71(A), adopted by the 60th session of the UNGA, para 7, the court stated that victims of serious violations of human rights and international humanitarian law must have equal and effective access to justice, must receive adequate, effective and prompt repatriation for the harm they have suffered.

Government Response to the Transitional Justice Scenario

While addressing the 79th session of UNGA 2024 in New York, former PM Kp Sharma Oli states, “As a nation emerging from conflict, Nepal deeply understands the profound value of peace and political stability. Since the signing of the Comprehensive Peace Accord in 2006, Nepal has been firmly focused on completing the peace process at the earliest. Immediately after the formation of my government, parliament passed a Transitional Justice bill to settle transitional justice issues once and for all. While we implement the law, we will uphold victims’ rights, including truth and justice. We will also use reparations and reconciliation to heal the wounds and scars of the conflict period. We appreciate support from the international community, including the UN system, in this regard”. 

Further, during Nepal’s third UPR cycle in 2021, Nepal received 233 recommendations, accepted 196 and noted 37, among which most of the recommendations were focused on strengthening the NHRC, establishing transitional justice mechanisms and improving cooperation with treaty bodies (UNHRC 2025). 

In the 4th cycle of UPR of  Nepal, Nepal addresses that CIEDP and TRC have been mandated to investigate matters relating to enforced disappearances and to investigate matters relating to other gross violations of HR, respectively (UNHRC 2025). It also addresses all the amendments which have been made by CIEDPTRCA on forming three members of the special court and the definition of gross violation of human rights.

Analysis and Conclusion 

It’s been twenty years since the signing of the Comprehensive Peace Accords. The formation of the Enforced Disappearances Enquiry, Truth and Reconciliation Commission Act, 2014, came as a hope for the victims to obtain justice. However, even after struggling pre-conflict and post-conflict periods, justice has still not been served. Initially, the commission was formed for two years with the clause that the tenure shall be increased based on the fulfillment of its functions. However, the existence of the commission for two decades clearly states the incompetence of the organization.

Even though the EDETRCA have stated about the fair and transparent investigation, the victims of conflicts are still fighting for justice. Repatriation is a major aspect of providing relief to the victim in accordance with EDETRCA, but the realities of victims reflect the opposite. In fiscal year 2019-2020, Bagmati Province rolled out a 50 million rupee relief program targeting conflict victims. However, not even half of the money could be spent as the programme was designed without consulting possible beneficiaries (Kathmandu Post March, 2025). These realities of victims state that all the programmes for repatriation and restoration have not served victims yet and are useless. 

Further, Nepal is party to almost all core human rights treaties. Article 9 of the Nepal Treaty Act 1990 states that, in case of the provisions of a treaty, to which Nepal or the Government of Nepal is party upon its ratification, accession, acceptance or approval by the Parliament, the provisions of the treaty shall be enforceable as good as Nepalese laws. According to these provisions, Nepal is obligated to follow all the provisions set forth under International Human Rights laws to which Nepal is a party to. 

The Supreme Court of Nepal acts as the supreme and only body to ensure justice to the victims through its precedent. Through its precedent set forth under Rajendra Dhakal V. GON, Rajendra Ghimire V. Office of the Prime Minister and Others, Rajaram Dhakal V. Office of the Prime Ministers and Others, Madhav Kumar Basnet V. Government of Nepal, it has recognized the significance and obligation of Nepal in compliance with International Human Rights laws. Even after such reforms of laws, policies through international conventions, UN bodies, assistance of other states and precedents set forth by the Supreme Court of Nepal, Nepal still falls far behind in implementing such laws under procedural aspects. Political instability, political interference, absolute autonomy to commission on providing amenities to predators, and lack of victims' representation in the TRC are the major causes for justice not being served even after decades. 

Delivering justice is not enough when the deliverance of such justice is after twenty years of waiting. These victims who have survived armed conflict have now died, and their generations have been increasingly withholding traumas from decade to decade. Hence, justice delayed is justice denied. 

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Abbreviations

• CAT: Convention Against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment

• CPN: Communist Party of Nepal

• CPA: Comprehensive Peace Accord

• CIEDP: Commission for the Investigation of Enforced Disappearance of Persons

• EDETRC: Enforced Disappearances Enquiry, Truth and Reconciliation Commission Act

• GON: Government of NepalTRC: Truth and Reconciliation Commission

• IHL: International Humanitarian Law

• IHRL: International Human Rights Law

• TRC: Truth and Reconciliation Commission

• UDHR: Universal Declaration of Human Rights

• UNGA: United Nations General Assembly

• UNHRC: United Nations Human Rights Council

• UPR: Universal Periodic Review

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Glossary

• CPN (Maoist): The Communist Party of Nepal-Maoist (CPN-M), was formed in 1995 following a split in the Communist Party of Nepal-Unity Centre. A radical faction led by Pushpa Kamal Dahal alias Comrade Prachanda and Baburam Bhattarai set up the CPN-Maoist and denounced the Communist Party of Nepal-Unified Marxist-Leninists (CPN-UML) and other mainstream communist factions as 'renegades' and 'revisionists' due to their participation in the parliamentary process.

• Comprehensive Peace Accord: CPA is a peace agreement reached between the Government

• of Nepal and the CPN (Maoist) with a commitment to transform the ceasefire between the Nepal Government and the CPN (Maoist) into long-term peace.

• 40 Point Demand: a collection of 40 demands by the CPN Maoist sent to the Government of Nepal, which, if not fulfilled, they will go to war. 

• Mandamus Order: A (writ of) mandamus is an order from a court to an inferior government official ordering the government official to properly fulfill their official duties or correct an abuse of discretion.

• Maoist insurgency: February 1996, the CPN (Maoist) launched an armed insurgency against the Government. Over the course of the following decade, what was initially regarded as a minor problem of law and order in a distant part of rural Nepal developed into an entrenched and often brutal armed conflict that affected the entire country.

• People’s movement: 19 days of widespread public demonstrations dubbed the Jana Andolan, or people's movement, ended King Gyanendra's year-long usurpation of all authority and created conditions conducive to a ceasefire in the brutal civil war between government forces and the Communist Party of Nepal-Maoists (CPN-M).

• Precedents: An adjudged case or decision of a court of justice, considered as furnishing an example or authority for an identical or similar case afterwards arising or a similar question of law. A draught of a conveyance, settlement, will, pleading, bill, or other legal instrument, which is considered worthy to serve as a pattern for future instruments of the same nature.

• Transitional justice: Transitional Justice (TJ) refers to a range of measures—judicial and non-judicial, formal and informal, retributive and restorative—employed by countries transitioning out of armed conflict or repressive regimes to redress legacies of atrocities and to promote long-term, sustainable peace. 

• Victim: the term “victim” refers to an identity, feeling and involves interests: the desire to gain social recognition, to seek justice, to benefit from repatriations, to influence public opinion, to highlight the guilt of perpetrators, etc. 

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References

1. Government of Nepal & Communist Party of Nepal (Maoist). (2006, November 21). Comprehensive Peace Accord, Article 5.2.4 , available at https://www.peace.gov.np

2. Madhav Kumar Basnet V. Government of Nepal, D.N. 9051, Year 2070, available at https://nkp.gov.np/full_detail/256

3. Martin Chautari. (2021, October 18). Red-faced Maobadis. Para2 available at https://www.martinchautari.org.np/blogs/red-faced-maoba

4. Office of the United Nations High Commissioner for Human Rights (OHCHR). (2012). Nepal conflict report 2012: Executive summary. United Nations. P.3 available at   https://www.ohchr.org/sites/default/files/Documents/Countries/NP/OHCHR_ExecSumm_Nepal_Conflict_report2012.pdf

5. Pariman Tamang vs. Government of Nepal, Writ No. 0238 of 2063 BS (2006 AD)

6. Rajendra Dhakal vs. Nepal Government, Writ: Certiorari/Mandamus, Writ No. 3575 of the Year 2059, Date of order: 2064/02/18 (BS).

https://giwmscdnone.gov.np/media/files/21021154913-TJ%20-%20report%202016-16_bj8zhyd.pdf

7. Rajaram Dhakal V. Office of Prime Minister and Others, D.N. 7274, Year. 2060 B.S., available at https://nkp.gov.np/full_detail/1244#

8. The Asia Foundation. (2017, October 18). The state of conflict and violence in Asia: Nepal. Para 1. Available at https://asiafoundation.org/wp-content/uploads/2017/10/Nepal-StateofConflictandViolence.pdf

9. The Kathmandu Post. (2025, March 26). Conflict victims seek reparations based on need, consultations. https://kathmandupost.com/national/2025/03/26/conflict-victims-seek-reparations-based-on-need-consultations

10. The Kathmandu Post. (2025, July 2). Conflict victims slam UN support for ‘flawed’ transitional justice bodies. Para 1, available at  https://kathmandupost.com/national/2025/07/02/conflict-victims-slam-un-support-for-flawed-transitional-justice-bodies

11. The Kathmandu Post. (2025, June 25). 19 years since the peace accord, no justice for conflict victims, para 2, available at https://kathmandupost.com/province-no-3/2025/06/25/19-years-since-the-peace-accord-no-justice-for-conflict-victims

12. United Nations Security Council. (2004, August 23). The rule of law and transitional justice in conflict and post-conflict societies: Report of the Secretary-General (S/2004/616). United Nations, Para 8, available at https://docs.un.org/en/S/2004/616

13. U.S. Department of State. (2016.). Transitional justice overview,para 1, available at https://2009-2017.state.gov/j/gcj/transitional/257566.htm

14. United Nations. (1948). Universal Declaration of Human Rights, Article 8, available at https://www.un.org/en/about-us/universal-declaration-of-human-rights.

15. United Nations. (1966). International Covenant on Civil and Political Rights,available at https://www.ohchr.org/en/instruments-mechanisms/instruments/international-covenant-civil-and-political-rights

16. United Nations. (1984). Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment. Available at https://www.ohchr.org/en/instruments-mechanisms/instruments/convention-against-torture-and-other-cruel-inhuman-or-degrading-treatment-or-punishment

17. United Nations General Assembly. (2005). Basic principles and guidelines on the right to a remedy and reparation for victims of gross violations of international human rights law and serious violations of international humanitarian law (A/RES/60/147), available at https://www.ohchr.org/en/instruments-mechanisms/instruments/basic-principles-and-guidelines-right-remedy-and-reparation

18. United Nations Human Rights Council (UNHRC). (2025). National report submitted in accordance with Human Rights Council resolutions 5/1 and 16/21: Nepal (A/HRC/WG.6/51/NPL/1). https://docs.un.org/en/A/HRC/WG.6/51/NPL/1 , pg. 2