'serious'. The Complainant further states that the medical and psychological examination of the Victim carried out by Prof. Dr. Hans Petter Hougen and Dr. Onder Ozkalipci at the Department of Forensic Medicine of the Faculty of Health Sciences at the University of Copenhagen on 26 April 2010 documents a number of scars on the Victim's head, chest and forearms, left wrist and left thigh. He states that among the report's findings are the following conclusions: 116. That, 'the psychological symptoms that Gabriel Shumba shows are consistent with all criteria for post traumatic stress disorder, PTSD which is a disorder that regularly appears after torture'. 117. That the psychological report by Mr. Malose Langa is based on the provision of counseling services to the Complainant over a period of two years. The Complainant argues that the report sets out in detail the continuing psychological impact of the violations alleged by the Victim, including the observation that, 'it was also evident in our therapy sessions that Mr Shumba's sense of self-worth, dignity and respect has been damaged'. He states that Mr. Langa sets out that in terms of his clinical assessment, Mr. Shumba met the diagnostic criteria for Posttraumatic Stress Disorder (PTSD) with strong features of depression, anxiety, and alcohol abuse. He states that Mr Shumba was put on medication to help him deal with some these symptoms. He furthers states that it was evident in seeing Mr. Shumba for therapy that torture is an inhumane act that has deleterious effects, both physical as well as psychological, on the person being tortured. 118. The Complainant further states that Dr. Anthony Reeler, who worked with and knew the Victim prior to his alleged torture and ill- treatment and was involved with his treatment in South Africa, found that 'on the basis of my lengthy experience in the field of torture, as well as my clinical observation of Mr. Shumba before and after his return to Zimbabwe, I can state with very high degree of confidence that he exhibited most of the symptoms of Post-Traumatic Stress Disorder (PTSD) consonant with his story of being tortured'. 119. The Complainant argues that the medical and psychological reports refute the Respondent State submission that 'in the absence of the documentary evidence' his allegations of torture 'remain say-so'. He avers that the African Commission and the Respondent State in particular have repeatedly emphasized the probative value of medical and psychological evidence in determining whether torture and other ill-treatment has taken place. 120. The Complainant's avers that the allegations are further supported by a range of reports by the United States Government; non-governmental organizations specialized in the investigation and documentation of human rights violations; and the reports of international and national media houses. He states that these sources were included with the original submission and additional sources are attached to this Submission. 121. In an attempt to rebut the Respondent State arguments, that it would appear that allegations about persons allegedly tortured as stated by the Complainant, are based on newspaper reports which are specifically barred in terms of Article 56(4) of the Charter, the Complainant states that Complainants may not rely exclusively on the mass media. The Complainant submits that the U.S. State Department report and the reports of non-governmental organizations are not reports of the mass media, but reports by independent entities and experts in human rights investigation and reporting. He further argues that media reports can and are routinely accepted as evidence by the African Commission when used in conjunction with other evidences. He avers that Article 56(4) of the Charter only prohibits the exclusive reliance on such sources. The Complainant state that in this case, the Victim does not rely solely on media sources, but submits them along with the governmental and non-governmental reports of his treatment; personal affidavits; and extensive medical and psychological documentation. 122. The Complainant submits that he has provided more than adequate evidence to support the Victim's allegations of torture and ill-treatment He notes that in seeking to refute the Complainant's allegations, it is not sufficient for the Respondent State to simply argue that they are unsubstantiated when they are supported by range of documentation. Rather, he argues, the Respondent State must provide evidence to the contrary. In this case, the Complainant points out that the Respondent State arguments are not accompanied by any supporting documentation or evidence and do not advance any alternative explanation to counter the Victim's allegations. 123. In conclusion the Complainant request that the African Commission, in line with its long-standing and established practice, accept the Victim's allegations and find that the Respondent State violated Article 1 of the African Charter red in conjunction with Article 4, 5, 6, 7 and 10(1). 124. He avers that in meeting its obligations under the African Charter and international law generally that the Respondent State provides an effective remedy, full and adequate reparation that is appropriate and proportionate to the gravity of the crimes committed and the physical and mental harm that the Victim has 14