actio popularis principle has been confirmed in various subsequent decisions of the Africa Commission.9 79. Also in relation to the requirement of citizenship, the African Commission has made it clear through its jurisprudence that the person or NGO filing the Communication need not be a national or be registered in the territory of the Respondent State. An endless list of examples of this would include the many AC HP R cases submitted to the African Commission by individuals and NGOs of nonAfrican origin. 10 80. The African Commission, therefore, notes that the foregoing was its approach to locus standi when it became seized of the present Communication, and is still its current approach to the issue. Accordingly, the African Commission would address this Communication in light of its broad approach to locus standi at the time it became seized of this Communication. 81. The African Commission further disagrees with the Respondent State‟s assertion that neither the laws of Botswana nor international law incorporates the actio popularis doctrine, and notes that this is a common practice within regional and international human rights systems which is aimed at conferring legal standing to certain groups who will not be required to have a sufficient interest in a case or to maintain the impairment of a right. To this effect, different bodies had setup different criteria with regards to accessibility to their complaint mechanisms. The African Commission notes that, the European human rights system11 and the UN Human Rights Committee,12 generally requires that the 9 Communications No. 64/92, 68/92, 78/92, Kristan Achutcan on Behalf of Aleke Banda, Amnesty International on behalf of Orton and Vera Chirwa v. Malawi; Communications No. 54/91, 61/91, 98/93, 164-169/97, 210/98, Malawi African Association and others v. Mauritania . 10 See for instance Communication 31/89, Maria Baes/Zaire, instituted by a Danish national and Communication 235/2000 – Curtis Doebbler/ Sudan instituted by an American citizen. 11 See Article 34 of the European Convention on Human Rights 17