On 22 April 2015, the General Court, in Tomana & Others v Council & Commission, Case T-190/12, rejected an application for the annulment of three pieces of EU legislation concerning restrictive measures in respect of Zimbabwe. The relevant EU legislation – (1) Council Decision 2012/97/CFSP, (2) Commission Implementing Regulation (EU) No 151/2012, and (3) Council Implementing Decision 2012/124/CFSP – imposed sanctions on 121 persons for either (i) being members of, or members associated with, the Zimbabwean government or (ii) seriously undermining democracy, respect for human rights and the rule of law in Zimbabwe. (The restrictive measures have been suspended in respect of these persons since February 2014.)

The applicants relied on five pleas in law to support their application, claiming: (1) there was no proper legal basis for including persons or entities who are neither leaders of Zimbabwe nor their associates on the list of persons subject to restrictive measures; (2) there was a manifest error of assessment; (3) the obligation to state reasons was infringed; (4) the applicants’ right of defence was infringed; and (5) the principle of proportionality was infringed. The General Court rejected all five of the applicants’ pleas and dismissed the action.