State Parties. But even in the case of the latter, the Commission holds the view that the Charter applies primarily within the territorial jurisdiction of States Parties. This is simply because the sovereignty of states with which they undertake international obligations is territorial, and the jurisdiction they exercise in discharge of those obligations is equally primarily territorial. However, as noted above, circumstances may obtain in which a state assumes obligations beyond its territorial jurisdiction such as when a state assumes effective control of part of a territory of another state (spatial model of jurisdiction)14, or where the state exercises control or authority over an individual (personal model of jurisdiction).15 The Commission does not find it necessary to elaborate further on the circumstances under which a State Party may assume obligations extraterritorially. 135. It suffices to state however that a Complainant must establishment a sufficient connection between the alleged violation and the Respondent State before the Commission can proceed to invoke the obligations of that state under the Charter with a view to assessing whether such obligations were breached. 136. For purposes of admissibility a Complainant can establish the sufficient connection by proving that he or she was under the territorial jurisdiction or effective control or authority of the Respondent State when the alleged violation occurred. A classic example of the latter is the case of a state occupying part of the territory of another state as was held by the International Court of Justice in the Case concerning armed activities on the territory of the Congo (Democratic Republic of the Congo v Uganda) (Judgment of 19 December 2005) ICJ para 178. 137. In this regard, the Commission has held that whereas the question “whether the alleged violations were committed by state actors directly or by private individuals is something that would be looked into at the merits stage, at [the admissibility stage] it suffices to prove that the alleged violation occurred within the territorial jurisdiction of the Respondent State”.16 General Comment 31 “Nature of the General Legal Obligation Imposed on States Parties to the Covenant” Human Rights Committee (2004) para 10; Loizidou v. Turkey, (preliminary objections), (1995) ECHR (App. No. 15318/89); Loizidou v. Turkey, (merits) (1996) ECHR (App. No. 15318/89); Legal Consequences of the Construction of a Wall in the Occupied Palestinian Territory, Advisory Opinion (9 July 2004) ICJ paras. 108-111; and Armed Activities on the Territory of the Congo (Democratic Republic of Congo (DRC) v. Uganda), (19 December 2005) ICJ, both of them cited in Al-Skeini & others v The United Kingdom (2011) ECHR (Application No. 55721/07) paras. 90-91; 15 Communication 52/79 - Lopez Burgos v. Uruguay (1981) HRC, General Comment 31, n 13 above para 10. On extraterritorial application of state’s human rights obligations, see further Marko Milanovic, Al-Skeini and Al-Jedda in Strasbourg, (2012) The European Journal of International Law Vol. 23 no. 1 p.121 at 122 < http://ejil.oxfordjournals.org/content/23/1/121.full.pdf> (accessed 21January 2014) 16 Communication 306/05 - Samuel T. Muzerengwa & 110 Others v Zimbabwe (2011) ACHPR para 58 14 26