Arbitral Award No. 98/CNO/LH/006 of 1 April 1998 issued by the National Bar Council. 133. Having found that the rights protected under Articles 3, 7 (1) (a) and 7 (1) (c) of the African Charter have been violated, the Commission responded to Complainant’s allegations. The Commission remains committed to the fundamental principle of compensation on the basis that the series of rights guaranteed by the African Charter would be an empty proclamation if it was not backed by the guarantee of a right to restitution or compensation in the event of violation. Although in the past the Commission has moved cautiously when it came to the rights to remedy and reparation, it has progressively built a jurisprudence which, in practice, has grown ever stronger. The doctrine also recognizes jurisprudential developments subsequent to the Commission as an acceptance of the principle of restitution and compensatory damages. 39 The edicts of the Commission on the issue of rights remedy and reparation are also many and varied, and include such simple recommendations as: “take steps to remedy the harm suffered”,40 “release detainees”,41 and “restore the victim’s right.”42 134. Regarding the specific issue of monetary compensation, the decisions of the Commission in the cases of Embga Mekongo Louis v. Cameroon43 and Antoine Bissangou v. Congo44 seem to be closest to the present Communication. Such recognition of the right to reparation, including monetary compensation, should not overshadow the consistent position that the role of the Commission is not to act as a court of first instance or national court. The Commission is not a court of appeal vis-à-vis national courts whose decisions it would be called upon to annul, revise or revoke. However, the Commission is established by the African Charter as a quasi-judicial body for overseeing the conformity of the national practices of States and their internal organs, with their obligations under the African Charter. 135. Such a position did not prevent the Commission from specifying the form and content of compensation in cases where the Complainant’s request was See G Naldi “Reparations in the Practice of the African Commission on Human and Peoples’ Rights” (2001) Leiden Journal of International Law 686-688 and H Adjolohoun Human rights and Constitutional Justice in Africa: The Beninois Model in Light of the African Charter on Human and Peoples’ Rights, Paris: Harmattan (2011) 58-72. 40 Abubakar v. Ghana Communication 103/93 (2000) RADH 116 (CADHP 1996) para 17. 41 Constitutional Rights Project and Civil Liberties v. Nigeria Communication 143//95, 150/96 (2000) RADH 234 (CHPR 1999) para 56. 42 Pagnoulle (on behalf of Mazou) v. Cameroon Communication 39/90 (2000) RADH 61 (CADHP 1997) para 31. 43 Communication 59/91 (2000) RADH 60 (CADHP 1995) para 2. 44 Communication 253/02 (2006) AHRLR 80 (ACHPR 2006). 39 27