Alleged violation of the right to adequate housing, a combined reading of Articles 14, 16 and 18 120. At this stage, the Commission has to determine if there is a right to adequate housing under Article 14 of the African Charter read together with Articles 16 and 18, in which case it will be important to determine if the facts of the case constitute a violation of the right to adequate housing. Article 16 of the African Charter stipulates that: “Every individual shall have the right to enjoy the best attainable state of physical and mental health.” Article 18 stipulates that: “The family shall be the natural unit and basis of society. It shall be protected by the State which shall take care of its physical and mental well-being”. 121. Regarding the existence of a right to adequate housing, the Commission notes that the right to property under Article 14 of the African Charter has to be understood at least using the three broad, inclusive and interdependent approaches. With the broad approach, the right to property has to entail the traditional possibility to include a wide range of subsequent rights such as usus, fructus and abusus. Moreover, and in particular, property ownership is typical in that its ultimate objective is to meet the need to provide housing, and housing is one of the most fundamental human rights.33 122. With the inclusive approach, the Commission is of the view that the right to property is governed by the famous saying that “the accessory follows the principal”. In this regard, since the ownership of land carries that of what is above and below, the projects and other activities undertaken by the owner to develop the land cannot reasonably be excluded from an objective and holistic definition of property. Regarding the interdependent approach to the right to property, it is defined as the relationship of this right with other rights of the African Charter. As such, it will be difficult for the individual who owns this right to enjoy other rights such as the rights to health and to education in the absence of adequate housing. In all likelihood, an individual without shelter will not be able to enjoy the best attainable state of physical and mental health guaranteed by the African Charter. In any case, since housing is one of the fundamental human rights,34 it contributes to the realisation of the right to live in one’s own house. 123. In its jurisprudence on the right to property, the Commission recognises the right to housing as a right deriving from a combined reading with the right to the best attainable state of physical and mental health guaranteed See Universal Declaration of Human Rights, Article 25(1); International Covenant on Economic, Social and Cultural Rights, Article 11(1). 34 See UDHR, ICESCR, op. cit. 33 28