under Article 16 of the African Charter. Particularly in the case of SERAC v. Nigeria, the Commission concluded that “although the right to housing or shelter is not explicitly provided for under the African Charter, the corollary of the combination of the provisions of Articles 14, 16 and 18(1) of the African Charter makes it an implicit right”.35 The interdependent approach to the right to property mentioned above is in line with the spirit of this jurisprudence. Indeed, the right to property cannot be violated without violating the corollary rights, including its adjoining and dependent rights in particular such as the right to housing, physical and mental health, as well as the well-being of the family. 124. In this case, the Commission notes that the Complainant, her husband and their children undertook to buy the land in question in order to build a house. In doing so, they took a bank loan and the building of a hut on the land was only a step towards achieving their ultimate objective of developing the land. By destroying or allowing the destruction of the hut, the Respondent State and its employees destroyed or at least frustrated the project to realise the right to adequate housing. In the circumstances of the case, the Commission is of the view that such acts constitute a violation of both the provisions of Articles 16 and 18 of the African Charter and the right to adequate housing arising therefrom following a combined interpretation. Alleged violation of Article 1 125. The Complainant further claims that the Respondent State violated Article 1 of the African Charter since it failed to prevent third parties from stopping her from realising her right to property and her right to adequate housing. In this regard, the Commission recalls its jurisprudence and notes that in principle, a violation of any provision of the African Charter automatically means a violation of Article 1”.36 126. However, it is important to understand the obligation under Article 1 of the African Charter which provides for both a legislative or administrative undertaking of a legal nature as well as a “commitment” to give effect to the rights enshrined in the African Charter. It is obvious that there are two obligations under Article 1 of the African Charter: an obligation of means and of result. In this case, the Commission notes that the Respondent State adopted a number of laws and regulatory standards to organise and govern real estate transactions and in particular the obtaining of land certificates. SERAC v. Nigeria op. cit. para 60. See, among others, Jawara v. The Gambia Communication 147/95 and 149/96 (2000) AHRLR 107 (ACHPR 2000) para 46; Association des Victimes des Violences Post-Electorales and Interights v. Cameroon Communication 272/03 (2009) AHRLR 47 (ACHPR 2009) para 105-115. 35 36 29