The Request alleges that the Project is perpetuating historical injustices against the Batwa people, claiming that the Project has systematically excluded the Batwa people from meaningful participation and proper consultations. According to the Request, Project consultations were flawed as there was no proper indigenous representation present, thus legitimizing the continued marginalization and exclusion of the Batwa people, who were in the past displaced from their traditional forests, leaving them landless and without resources. The Request also claims that although the Project presents opportunities for co-management and benefit-sharing that could address decades of marginalization, the Batwa people were never allowed to come to the table to negotiate co-management arrangements and benefit-sharing that could provide sustainable livelihoods for communities. It also claims that Batwa communities are being treated as “obstacles” rather than partners in conservation and tourism as the traditional forest knowledge of Batwa communities is being sidelined by the Project although it is an invaluable resource.
The Request claims that non-Indigenous intermediaries and government entities collect and benefit from tourism revenues, while Batwa identity and heritage is treated like a commodified resource. It alleges that Project-supported tourism exploits Batwa culture and the individuals selected to perform cultural practices, while at the same time Batwa communities are excluded from revenue-sharing, which amounts to cultural exploitation and forced assimilation. The Request adds that without a meaningful share of the benefits generated in their traditional territories the communities remain impoverished.
The Request further alleges that the Project’s acceptance of unauthorized representation has created divisions between Batwa leaders and settlements weakening their collective voice and unity. The Request has raised concerns about intimidation and reprisals, alleging threats to the safety of Batwa representatives for asserting their rights.
The Panel conducted its initial due diligence for the Request and met with the Requesters on September 24, 2025, and October 2, 2025, and with Bank Management on October 1, 2025. The Panel determined that the Request meets all applicable admissibility criteria and on October 14, 2025, the Panel registered the Request. Management provided its response to the allegations made in the Request on December 1, 2025. A Panel team visited Uganda on November 6-11, 2025 to meet with the Requesters and on December 1-6, 2025 to meet with the World Bank staff and Project’s Implementing Unit. These visits inform its report and recommendation to the Board of Executive Directors
On January 9, 2026, the Panel in its report recommended an investigation into some of the alleged issues of harm in the Request for Inspection and related possible noncompliance with the applicable World Bank policies. The Panel determined a plausible link between the Requesters’ allegation with respect to the Project perpetuating the marginalization and exclusion of the Batwa in relation to their ancestral claim to access natural resources in the forests from which they were evicted. However, the Panel excluded from its recommendation to investigate claims made in related to compensation, land and restitution of historical evictions as they fall outside the Project’s scope and, thus, the Panel’s mandate. The Panel also determined that the alleged harm associated with tourism-related revenue-sharing schemes is also not directly linked to the Project.
On January 23, 2026, the Board approved, on a no objection basis, the Panel’s recommendation to investigate the Bank in relation to the Project and the allegations raised in the Request. Under the World Bank Accountability Mechanism Resolution, after Board approval of the Panel’s investigation recommendation, the Head of DRS offered the Requesters and the Borrower the option of Dispute Resolution. On March 9, 2026, the Head of DRS informed the Panel that the Parties did not agree to pursue Dispute Resolution. Pursuant to paragraph 32 of the AM Resolution, the Inspection Panel commences its investigation following this notification.
