made it clear, inter alia, in WOAT/OMCTs vs. Zaire2 that the author of a Communication need not be the victim nor related to the victim(s) of the human rights violations alleged. This position is put succinctly in the Commission‟s decision in Malawi African Association and Others v Mauritania3, where it held that “Article 56(1) of the Charter demands that any persons submitting communications to the Commission relating to human and peoples‟ rights must reveal their identity. They do not necessarily have to be the victims of such violations or members of their families. This characteristic of the African Charter reflects sensitivity to the practical difficulties that individuals can face in countries where human rights are violated. The national or international channels of remedy may not be accessible to the victims.”4 63. As a result of the foregoing, the Commission is disagrees with the Respondent State‟s argument that the Institute lacks legal interest in the matter. 64. With respect to the argument of the Respondent State that the Institute is not a citizen of or an organization registered in Ethiopia, the Commission made it clear in Spilg and Mack & DITSHWANELO (on behalf of Lehlohonolo Bernard Kobedi)/ Botswana5 that the person or NGO filing the Communication need not be a national or be registered in the territory of the Respondent State. There is no requirement of “citizenship” for the authorship of a Communication. 6 Any interested individual or organisation can bring a Communication on behalf of a victim and such individual or organisation need not be a citizen or be registered within a States party to the African Charter. 65. Thus, the fact that the Institute is not registered in Ethiopia is immaterial. As long as it satisfies the conditions set out in Article 56 of the African Charter, the African Commission will entertain the Communication as it has done, in several other cases where 2 Communications No. 25/89, 47/90, 56/91, 100/93. Communications: 54/91, 61/91, 164/97 to 196/97, 210/98. 4 Ibid, (Comm: 210/98) para 78. 3 5 Communication 277/2003. See also Communications 54/91, 61/91, 98/93, 164/97 to 196/97, 210/98 – Malawi African Association, Amnesty International, Ms Sarr Diop, Union Interafricaine des Droits de l‟Homme and RADDHO, Collectif des Veuves et Ayants-droit, Association Mauritanienne des Droits de l‟Homme/Mauritania. See e.g., cases submitted by Amnesty International, Interights, and also Communication 31/89, Maria Baes/Zaire, instituted by a Danish national and Communication 235/2000 – Curtis Doebbler/ Sudan instituted by an American citizen. 6 See generally, “Capacity to Bring a Communication before the African Commission on Human and Peoples‟ Rights (Locus Standi)”, Working Document of the African Commission, 40 th Session, 15th-29th November 2006, Banjul, The Gambia. 11