effective protection of the right to property protected under Article 14 of the African Charter.30 109. In this case, whereas the Complainant holds a land certificate which she deems valid, the Respondent State considers that the said land certificate lost its opposability to third parties as a result of the annulment of her vendor’s land certificate. In order to resolve this aspect of the dispute, the Commission will start by verifying if the Complainant holds a valid land certificate in accordance with the relevant laws before considering the cogency of the loss of opposability as argued by the Respondent State. 110. The Commission will begin by verifying if the Complainant followed the established procedure for obtaining a land certificate in Cameroon and, as appropriate, what the legal consequences are. In this regard, the Commission notes that under the law cited above, applications to convert various deeds into land certificates shall be submitted to the Provincial Head of Service of Land Tenure of the locality where the property is situated and have to meet certain format requirements. The same law provides that the notary who draws up the sales deed shall submit to the Land Registrar of the locality where the property is situated a file containing the required documents, including the situation plan of the property duly signed by the Divisional Head of Service of Land and Surveys. 111. The Commission notes in particular that Article 30 of the Decree cited above stipulates that: “Before converting deeds into land certificates, the Land Registrar shall verify the documents submitted and ensure the identity and capacity of the parties and the availability of the property”.31 It emerges that the sworn authorities of the Respondent State cannot issue a land certificate on a property without verifying if the procedure is in compliance with the law. Moreover, and in particular, the said authorities are obliged to refrain from issuing a land certificate unless they have verified the availability of the property, that there is no dispute and that it indeed belongs to the vendor. 112. In the present case, the Commission notes that the Respondent State does not at any given time dispute the legality of the procedure followed by the Complainant to buy the property or obtain a land certificate. In fact, the Complainant contacted the competent authorities who made the necessary verifications and duly issued a land certificate. As such, the land certificate was opposable to third parties and the State. Regarding the resulting legal implications, the land certificate obtained by the Complainant became See Centre for Minority Rights Development and Minority Rights Group v. Kenya (2009) AHRLR 75 (ACHPR 2009) para 205. 31 Highlighted by the Commission. 30 25