The Admissibility of Subregional Courts’ Decisions before the African Commission. .. 255 the Human Rights Committee did not reject it on the grounds of prior examination. Rather, the Committee’s finding of inadmissibility was based on the author’s failure to substantiate his or her communication. Through reservation, some countries exclude the Human Rights Committee from examining communications in which ‘the same matter has already been examined under other procedures of international investigation or settlement.’94 Where such reservation exists, the Human Rights Committee does not admit communications pending before or decided by other international tribunals. Such reservation ‘sets forth the principle of non bis in idem.’95 This principle bars blaming a state twice for the same violation. Among African countries, only uganda made similar reservation under the ICCPR.96 The reservation precludes the Human Rights Committee from reviewing cases against uganda that have already been decided by subregional and regional judicial or quasi-judicial bodies such as the East African Court of Justice, African Commission, the African Court or the African Committee of Experts on the Rights and Welfare of the Child. The second category of human rights bodies does not admit a case that has already been decided although they admit a case that is pending before other international bodies. Unlike the first category, simultaneously duplicating procedures are allowed under this category. The advantage of such a requirement is to avoid the ‘unsettling possibility of divergent “conclusions” to a particular matter before different bodies.’97 94 These countries Austria, Croatia, Denmark, France, Germany, Iceland, Ireland, Italy, Luxembourg, Malta, Norway, Poland, Romania, Russia, Slovenia, Spain, Sweden , Turkey, Uganda, El Salvador, Moldova, and Sri Lanka. They are mostly European countries. See Reservation under the Optional Protocol to ICCPR, available at <http://treaties.un.org/Pages/ViewDetails.aspx?src=TREATY&mtdsg_no=IV5&chapter=4&lang=en#2Some > (accessed on 11 February 2013). 95 O.F. v Norway. 96 Frans Viljoen ‘Communications under the African Charter: Procedure and Admissibility’ in Malcolm Evans & Rachel Murray (eds) (2008), The African Charter on Human and Peoples’ Rights: the System in Practice 1986-2006 (Cambridge: Cambridge University press), p. 127. The reservation provides that ‘Uganda does not accept the competence of the Human Rights Committee to consider a communication under the provisions of article 5 paragraph 2 from an individual if the matter in question has already been considered under another procedure of international investigation or settlement. ’ See <http://treaties.un.org/Pages/ViewDetails.aspx?src=TREATY&mtdsg_no=IV5&chapter=4&lang=en#EndDec> (accessed on 7 February 2013). 97 Ibid, p.126.