unassailable, inviolable and final. However, the Complainant’s right to property has to be free from any of the exceptions to inviolability. 113. The exception raised by the Respondent State relates to the loss of opposability to third parties as a result of the annulment of the vendor’s land certificate. The Respondent State raises the issue of fraud by the holder of the land certificate, the vendor, which under the relevant laws makes the land certificate liable to withdrawal by the Minister of Land Tenure. The Respondent State contends that the fraud was penalised by the court which withdrew the Ordinance granting the vendor’s land certificate, and following which the competent Minister withdrew the said land certificate. The Respondent State maintains that as a result, the Complainant should have filed a fraud suit for damages against the vendor who committed fraud. 114. Regarding this argument, the Commission recalls its decision in the case of SERAC and Another v. Nigeria to state that the nature of the obligations of States under the African Charter is not only to respect rights but also to guarantee their protection, fulfilment and promotion.32 The obligation to respect requires States to refrain from participating directly in committing violations, while the obligation to protect requires intervening to prevent these rights from being violated. Regarding the obligations to fulfil and to promote, they require implementing the necessary measures for the effective enjoyment of the guarantees provided for by the law. 115. In this case, the Commission notes that since the land certificate issued to the Complainant was fully valid under the relevant laws, no error involved in the procedure for issuing the document can encumber the right of the Complainant who scrupulously complied with the legal requirements under the supervision of sworn government authorities. It would be unjust for buyers of good faith to be left in total legal insecurity, at the mercy of vendors who commit fraud and dishonest competent authorities who allowed the fraud that is subsequently alleged. In this case, the fraud committed by the vendor which the Respondent State raises falls under the full responsibility of the authorities who issued the land certificate that was later annulled, and thus entails the responsibility of the Respondent State. 116. The Commission notes that instead of fraud on the part of the beneficiary, it should be a question of “error on the part of the Administration as a result of an irregularity occasioned during the procedure for obtaining the land certificate and with regard to authentic documents”. The relevant laws of the Respondent State provide for such administrative error as an exception to the 32 See SERAC and Another v. Nigeria Communication 155/96 (2001) AHRLR 60 (ACHPR 2001) para 44. 26