the African Charter;25 (c) the Communication should be brought in respect of violations that occurred after ratification of the African Charter or where violations that began before the State Party ratified the African Charter have continued even after such ratification.26 To be in conformity with the African Charter also requires the petition to contain a certain degree of specificity, and that the allegations are not vague.27 A careful consideration of the facts and submissions from both parties to the AC HP R 101. present Communication do not show that the instant Communication is at variance with any part of the Constitutive Act of the African Union or the African Charter. The Commission is therefore of the view that the present Communication satisfies the provision of Article 56 (2) of the Charter. 102. Article 56(3) of the African Charter requires that the Communication should be presented with a certain degree of decorum. This Article prohibits the use of disparaging and/or insulting language in presenting a Communication. Although Article 56(3) does not define what constitutes disparaging or insulting language, the African Commission in the case of IIesanmi v. Nigeria28 the Commission held inter alia, that, to be insulting, the language must be aimed at undermining the integrity and status of the institution (Respondent State) and bring it into disrepute.29 In this case, the African Commission held the Complainant‟s averments that, “the police and customs officials are corrupt, that they deal with drug smugglers, that they extort money from motorists and that the President himself was corrupt and had been bribed by the drug smugglers” as an insulting language. In Ligue Camerounaise des Droits de l’Homme v. 25 Communication 1/88, Frederick Korvah V. Liberia, (ACHPR) Communication 97/93, John K. Modise (2) V. Botswana (ACHPR) 27 Communication 35/89, Seyoum Ayelle V. Togo, Paragraph 2 (ACHPR) See also, Communication 142/94, Muthuthurin Njoka V. Kenya, Paragraph 4 (ACHPR) 28 Communication 268/2003, (ACHPR) 18th Activity Report 29 Ibid, Para. 39 26 24