interference by third parties as well as its own agents. This obligation is also reflected in the Commission's Resolution= which states that the States have obligation to respect and protect 'against any form of encroachment', and to 'refrain from and prevent forced evictions, including by private actors. It also prohibits States 'from interfering arbitrarily in the enjoyment of property rights, including expropriation without legal grounds or which is not performed in the public interest. 180. In this regard, in Zimbabwe Human Rights NGO Forum/Zimbabuiev the Commission noted that an act by a private individual or [non-state actor] and therefore not directly imputable to a State, can generate responsibility of the State, not because of the act itself, but because of the lack of due diligence on the part of the State to prevent the violation or for not taking the necessary steps to provide the victims with reparation. 181. In Sudan Human Rights Organisation & Centr,~/\qllHousing Rights and Evictions (COHRE) / Sudan, the property of the victims Had been destroyed by the State's military forces and armed groups, acting on their own, or believed to be supported by the Respondent State. The Commission found the RespondentState in violation of Article 14 because the State could not prove that it-refrained from the eviction, or demolition of victims' houses and other property, since it had not taken steps to protect the victims from the constant attacks and b9:mbings, and the rampaging attacks by the Janjaweed militia. The Commission stated that the fact that that the' victims could not derive their livelihood' from the land they possessed for generations meant th~Y;?l:1adbeen deprived of .the use of their property under conditions which are not permitted by Article 1454. 182. Regarding the second aspect of the Complainants' claim that the seizure of their lawyer's Passport violated his right to property, the Commission notes that the Passports and Immigration Act, 2011 of South Sudan gives the Directorate of Nationality, Passports. ~I1d Immigration under the directives of the Minister of Interior, authority to issue, cancel; or withdraw Passports, howbeit, in line with prescribed Regulations. The Commission is therefore of the view that although the aforementioned Act does not specifically mention so, under the law of most countries, passports are government property, given that they are governmentissued, and may therefore be limited or revoked at any time, usually on specified grounds, and possibly subject to judicial review. 183. 52 ACHPRI Res.23I , Resolution on the right to adequate housing and protection from forced evictions, adopted 22 October 2012. 53 Communication 245/2002, Zimbabwe Human Rights NGO Forum/Zimbabwe, paras 135. 143, and 160. 54 Communication 279/03-296/05, paras 194 and 205 ir- Ordinary Session of the ACHrR 33

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