27. Associations shall be able to comment publicly and privately on reports submitted by states to national human rights institutions and regional and international human rights bodies, including prior to the submission of the reports in question.20 28. The right to freedom of association protects, inter alia, expression; criticism of state action; advancement of the rights of discriminated-against, marginalized and socially vulnerable communities, including the rights of women and children; and all other conduct permissible in the light of regional and international human rights law.21 29. States shall respect, in law and practice, the right of associations to carry out their activities, including those denoted above, without threats, harassment, interference, intimidation or reprisals of any kind.22 30. States shall protect associations, including their principal and most visible members, from threats, harassment, interference, intimidation or reprisals by third parties and non-state actors. IV. Oversight Oversight Bodies 31. Matters relating to the oversight of associations shall be overseen, where necessary, by a single body that conducts its functions impartially and fairly.23 Such a body shall have oversight only in relation to essential, minimum internal governance express their views and participate in a meaningful, substantive manner. Consultation procedures shall take account of the fact that certain persons and groups face challenges in accessing information and disseminating their points of view, for instance due to marginalization, illiteracy, language barrier, disability, lack of internet access and/or geographical remoteness; proactive steps shall be taken to overcome these obstacles. 20 Comment may, inter alia, take the form of press release, public report, shadow report or private comments submitted to the organization in question. 21 See, e.g., International Pen and Others (on behalf of Ken Saro-Wira) v. Nigeria, Comm. Nos. 137/94, 139/94, 154/96 and 161/97 (1998), paras. 107-10 (finding a violation of the right to freedom of association where the government took action against an association due to disapproval of its actions). See also Monim Elgak, Osman Hummeida & Amir Suliman (represented by International Federation for Human Rights & World Organisation Against Torture) v. Sudan, Comm. No. 379/09 (2014), paras. 116-9. 22 On state harassment of individuals and associations due to their adoption of positions the authorities disapproved of, see Aminu v. Nigeria, Comm. No. 205/97 (2000), paras. 22-3; Huri-Laws v. Nigeria, Comm. No. 225/98 (2000), paras. 47-9; Ouko v. Kenya, Comm. No. 232/99 (2000), paras. 29-30; Monim Elgak, Osman Hummeida & Amir Suliman (represented by International Federation for Human Rights & World Organisation Against Torture) v. Sudan, Comm. No. 379/09 (2014), paras. 116-9. ‘Intimidation or reprisal’ means any form of violence, threat, retaliation, de facto or de jure adverse discrimination, pressure or any other arbitrary or detrimental action or threat related to status, or legitimate work or activity, including proposed, attempted or imputed work or activity. 23 Civil society actors may be included in this body as a means to promote transparency and fairness. 14 |  African Commission on Human and Peoples’ Rights