Communication 431/12 – Thomas Kwoyelo v. Uganda result of the delay and lack of medical treatment or injuries sustained during a beating while in detention. 279. The regular visits that he is allowed to have to the prison hospital, as conceded by the Complainant, to the contrary hint that he was at least receiving treatment when needed. 280. There are also no records of complaints lodged by the Complainant or the Victim requesting to get treatment; or against denial of treatment; or inadequacy of treatment. 281. As established above, the Complainant was also unable to make a case for torture, inhuman and degrading treatment, which if proven, could have made a case for violation of the right to health. 282. In light of the foregoing, the Commission finds no violation of Article 16 of the Charter by the Respondent State. Obiter Dictum 283. As it is evident from the analysis above on Article 3 of the African Charter, the amnesties granted in relation to the conflict in Northern Uganda was a bone of contention. In the light of that, in this obiter dictum the Commission addresses the issue of blank amnesties vis-à-vis the international and regional human rights obligations of States Parties to the Charter. 284. One of the issues at the core of this Communication concerned with the application of amnesty as an instrument of conflict settlement. In the case at hand, the Commission has confined its analysis to the issue of whether the application of the Amnesty Act complied with the requirements of the right to equality. Accordingly, the Commission did not examine the question of compatibility of the use of amnesty with the rights guaranteed in the African Charter. However, 75 62nd Ordinary Session, 25 April – 9 July 2018