absolutely opposable nature of an obtained land certificate. In any case, the error on the part of the Administration cannot be opposable to the Complainant who is a buyer of good faith. As a result, since the Administration is at fault, it had to shoulder the responsibility for the damage by redressing the damage suffered by the presumed true owner of the property. Otherwise, it would appear that the buyer of good faith was penalised for scrupulously complying with the laws and obtaining a land certificate validated with the seal of the State. 117. From the foregoing, it should follow that by allowing through its fault the competent court and Minister to take actions that undermine the tangible land certificate held by the Complainant, the Respondent State violated its obligation to respect the right to property guaranteed under Article 14 of the African Charter. 118. Supposing that the Complainant should have filed a fraud suit for damages against the vendor who committed fraud, the Commission is of the view that the Respondent State should first of all have met its obligation to verify the authenticity of the vendor’s land certificate which supposedly gave rise to the validity of the Complainant’s land certificate. It appears that despite the fact that the Complainant complied with the established procedure, government employees failed to detect the vendor’s alleged fraud and as a result failed to protect the Complainant. The obligation to protect was not also met afterwards given that despite the several complaints filed by the Complainant, the Respondent State did not take any action to initiate legal proceedings against its employees or the vendor who committed fraud. It should be concluded that the obligation to protect was violated. 119. Lastly, the Commission is of the view that the obligations to fulfil and to promote the right to property required the Respondent State to implement the relevant laws and take the necessary administrative and other measures to facilitate the practical enjoyment of the right in question. In this case, even if there is a relevant law governing the conditions for obtaining land certificates, the legal insecurity involved in the practical issuance of land certificates and the constant possibility to question a duly obtained land certificate undermine the fulfilment and promotion of the right to property. In this case, despite the fact that she scrupulously complied with the legal requirements, the Complainant, for close to seven years, was prevented from enjoying her property which was nevertheless duly bought and protected by a land certificate bearing the seal of the State. Under such circumstances, it should be noted that the Respondent State did not meet its obligations to fulfil and promote the right to property. 27