includes the investigation of an alleged crime, the arrest of the perpetrator and the bringing of him or her before a court. Allegation of violation of Article 4 of the African Charter 85. The Complainant alleged a violation of Article 4 of the African Charter. Article 4 of the African Charter provides that "human beings are inviolable. Every human being shall be entitled to respect for his life and the integrity of his person. No one may be arbitrarily deprived of this right". 86. The African Commission considers that the right enshrined in Article 4"is the fulcrum of all other rights. It is the fountain through which other rights flow, and any violation of this right without due process amounts to arbitrary deprivation of life."14 87. The Complainant claimed that numerous people were victims of extra-judicial or summary executions, attacks or attempted attacks against their physical integrity and acts of intimidation. Documents attached by the Complainant to support this claim include the judgment of the High Court of Zimbabwe in the Buhera North Election Petition; a list of persons who died between March 2000 and 31 December 2001 as a result of what it believed was politically motivated violence and extracts of newspaper articles. 88. The Complainant submitted further that some of the executions were carried out by ZANU (PF) supporters and war veterans but also that extra-judicial or summary executions carried out by any other State agents such as an officer of the Central Intelligence Organisation are also a violation of Article 4 of the African Charter. 89. The complainant further asserted that whether all levels of the Government were aware of the acts complained of or that such acts were outside the sphere of the agent's authority or violated Zimbabwean law was irrelevant for the purpose of establishing whether the respondent State was responsible under international law for the violations of human rights as alleged in the communication. The complainant maintained that the State is required under Article 1, to take all reasonable measures to ensure that people within its jurisdiction were treated in accordance with international human rights norms and standards15 . 90. Furthermore, the complainant averred that the right to life read together with the State's general obligation required by implication that there should be some form of effective official investigation when there has been an extra-judicial execution. This obligation is not confined to cases where it has been established that the killing was caused by an agent of the State16 . 91. The Complainant referred the Commission to the European Court decision in Jordan v the United Kingdom 17 which stated that "an effective official investigation must be carried out with promptness and reasonable expedition. The investigation must be carried out for the purpose of securing the effective implementation of domestic laws, which protect the right to life. The investigation or the result thereof must be open to public scrutiny in order to secure accountability. For an investigation into a summary execution carried out by a State agent to be effective, it may generally be regarded as necessary for the person responsible for the carrying out of the investigation to be independent from those implicated in the events. This means not only a lack of hierarchical or institutional connection but also a practical independence". 92. The complainant submitted that in the present communication there were no effective official investigations carried out in cases of extra-judicial or summary executions noting that this was because the very police which was implicated in failing to intervene and stop the murders were responsible for carrying out the investigations. The complainant referred the African Commission to its jurisprudence in several cases brought against Sudan with respect to the situation pertaining in that country between 1989 and 1993. In those communications, the African Commission held that "investigations into extra-judicial executions must be carried out by entirely independent individuals, provided with the necessary resources, and their findings must be made public and prosecutions initiated in accordance with the information uncovered"18 . Allegation of violation of Article 5 of the African Charter 93. The complainant also alleged a violation of Article 5 of the African Charter which provides that "every individual shall have the right to the respect of the dignity inherent in a human being and to the recognition of his legal status. All forms of exploitation and degradation of man particularly slavery, slave trade, torture, cruel, inhuman or degrading punishment and treatment shall be prohibited." 10