unsuitable, the related obligation results in compensation. In any case, the reparation has to be fair, adequate, effective, sufficient, appropriate, satisfactory to the victim and proportionate to the damage suffered.38 132. That said, restoration does not necessarily exclude an additional compensation. In order to restore the victim to the original situation, there is the need, including when dealing with property and cash, to return the property or return its value in the form of cash payment and also to compensate for the damage suffered as a result of the violation.39 As a result, fair reparation must not only include the restoration of the property, another property of a similar nature and of equal value or its equivalent in cash. 133. Moreover, the consequences of the violation have to be addressed to the extent possible, in particular through the payment of damages.40 The European Court of Human Rights recognises the relevance of an additional compensation to the primary reparation. Its relevant jurisprudence includes the case of Trévalec v. Belgium in which the Court decided to grant compensation for non-material damage in addition to the primary reparation obtained by the petitioner under an initial decision. The Court thus held that the primary reparation only partially addressed the damage suffered.41 134. In this case, the Commission notes that on the basis of the facts, with which the Respondent State fully agrees, the plot of land bought by the Complainant was taken from her by the judicial, political and administrative authorities and given to someone else whom they considered to be the true owner. The Commission has already decided on the opposability, in any case to the Respondent State, of the land certificate obtained by the Complainant. As a result, it should be further concluded that there was expropriation without grounds of public interest in favour of another individual. In accordance with established international jurisprudence adopted by the Commission, this is clearly a case of de facto expropriation in disguise; the reason being that the Respondent State had ownership over the land including the plot of land and contributed to the expropriation of the Complainant not in the general interest or in its own interest but in the See Loayza Tamayo v. Peru (1998), Velasquez (1989), Aloeboetoe v. Suriname (1993) of the Inter-American Court of Human Rights; Djot Bayi v. Nigeria (2009) of the ECOWAS Court of Justice. Also see, in general, REDRESS Reaching for justice: The right to reparation in the African Human Rights System (2013). 39 See S. Francq ‘L’influence du droit européen sur la réparation du dommage’ Cour de cassation https://www.courdecassation.fr/venements_23/colloques_activites_formation_4/2005_2033/europeen_ reparation_8066.html (consulted on 4 April 2015) 40 See Ch Quézel-Ambrunaz ‘Dommages et intérêts octroyés par la Cour européenne des droits de l’homme’ Revue des droits et libertés fondamentaux 2014, Chronique no 5. 41 See Trévalec v. Belgium Application No. 30812/07, Judgement of 25 June 2013 (ECtHR). 38 31