events was the 1999 Protocol of Understanding on Repatriation Mechanisms between the Dominican Republic and the Republic of Haiti. According to this document:234 […] d) The Dominican migration authorities recognize the inherent human rights of repatriates […]. e) The Dominican authorities shall provide each repatriate with a copy of the individual form containing the repatriation order. f) The Dominican migration authorities undertake to forward previously, within a reasonable time, to the Haitian diplomatic or consular authorities accredited on Dominican territory, the lists of people in the process of being repatriated. Those authorities may exercise their function of consular assistance. […] d) Collective expulsion 168. Article 22(9) of the American Convention establishes that: “The collective expulsion of aliens is prohibited.” 169. The Court has underlined that guaranteeing the content of Article 22 “is an essential condition for the free development of the individual.”235 170. Thus, it is relevant to observe that several international human rights treaties are consistent in prohibiting collective expulsions in similar terms to the American Convention.236 171. Under the inter-American system for the protection of human rights, the Court considers that the “collective” nature of an expulsion involves a decision that does not make an objective analysis of the individual circumstances of each alien and, consequently, incurs in arbitrariness. Similarly, the European Court of Human Rights has determined that a collective expulsion of an aliens is: 237 Any [decision] of the competent authority compelling aliens as a group to leave the country, except where such a measure is taken after and on the basis of a reasonable and objective examination of the particular cases of each individual alien of the group. 172. In consonance with the foregoing, the sheer number of aliens subject to expulsion decisions is not the essential criterion for characterizing an expulsion as collective.238 234 Protocol of Understanding on Repatriation Mechanisms between the Dominican Republic and the Republic of Haiti, signed on December 2, 1999 (file of annexes to the State’s final arguments, tome VII, folio 3916). 235 Cf. Case of Ricardo Canese v. Paraguay. Merits, reparations and costs. Judgment of August 31, 2004. Series C No. 111, para. 115 and Case of Velez Restrepo and Family Members v. Colombia, supra, para. 220. 236 Cf. Protocol 4 to the European Convention for the Protection of Fundamental Rights and Freedoms, Article 4: “Collective expulsion of aliens is prohibited”; the African Charter on Human and Peoples’ Rights, Article 12(5): “The mass expulsion of non-nationals shall be prohibited. Mass expulsion shall be that which is aimed at national, racial, ethnic or religious groups”; the Arab Charter on Human Rights, Article 26(2): “[…] Collective expulsion is prohibited under all circumstances”; the International Convention on the Protection of the Rights of All Migrant Workers and Members of their Families, Article 22(1): “Migrant workers and members of their families shall not be subject to measures of collective expulsion. Each case of expulsion shall be examined and decided individually.” See also United Nations Human Rights Committee, General Comment No. 15, para. 10: “Article 13 directly regulates only the procedure and not the substantive grounds for expulsion. […] On the other hand, it entitles each alien to a decision in his own case and, hence, article 13 would not be satisfied with laws or decisions providing for collective or mass expulsions”; Committee on the Elimination of Racial Discrimination, Concluding observations on the Dominican Republic, UN DOC. CERD/C/DOM/CO/12, 16 May 2008, para. 13: “The Committee is concerned at information received according to which migrants of Haitian origin, whether documented or undocumented, are allegedly detained and subject to collective deportations (“repatriations”) to Haiti without any guarantee of due process (arts. 5 (a) and 6).” 237 ECHR, Andric v. Sweden No. 45917/99. First Chamber. Decision of 23 February 1999, para. 1, Case of Conka v. Belgium. No. 51564/99. Third Chamber. Judgment of 5 February 2002, para. 59. 238 Cf. ECHR, Hirsi Jamaa v. Italy. No 27765/09. Grand Chamber. Judgment of 23 February 2012, para. 184. 48