of Expression in Africa.49 The Complainant argues that the African Commission has confirmed the fundamental importance of the right to freedom of expression in many of its decision, citing as examples: Constitutional Rights Project, Civil Liberties Organization and Media Rights Agenda v Nigeria,50 AmneshJ International v Zambia, 51 and Scanlen & Holderness v Zimbnbwe. 52 131. The Complainant contends that the right to freedom of expression constitutes an essential foundation of a democratic society and one of the basic conditions for its progress and for an individual's self-fulfilment is that the right may only be restricted in certain circumstances, and in conformity with international human rights standards. In support of this argument, the Complainant cites the decision of the African Court on Human and Peoples' Rights (African Court) in Konate v Burkina Faso, wherein the African Court held that a three-part test shouJd be applied in cases where freedom of expression is restricted: i) whether the restriction was provided by law; ii) whether the restriction served a legitimate purpose; and iii) whether the restriction was necessary to achieve the set objective.53 132. The Complainant submits that the restriction on his freedom of expression was not provided by law, and failed to meet the requirements under Article 9 of the African Charter and Article 39 of the Constitution of Sudan. Further submitting that his work highlighted instances of corruption and abuse by State agents, as such the lack of a formal charge against him is in itself evidence to show that his arrest and detention was not done in pursuit of any legitimate aim. Consequently, the Complainant submits that his arrest and detention were not provided by law, did not serve a legitimate purpose and was not necessary or proportionate. Alleged violation of Article 16 of the African Charter 133. The Complainant submits that the beating suffered, the inadequate care and treatment he received and the inappropriate conditions of detention harmed his physical and mental health in violation of Article 16 of the Charter. The Complainant argues that the United Nations Committee on Economic, Social and Cultural Rights in General Comment 14 directs States to ensure that detainees are afforded timely and appropriate healthcare. African Commission on Human and Peoples' Rights, Declaration of Principles on Freedom of Expression in Africa 2002 art 16. so Communication 105/93-128/94-130/94-152/96 Constitut' ,-i ;jg 4 "'· roject, Civil Liberties 0 ,1. ,p'°'~'i:-cfl.E. T "'~'4r"" ~ Organization and Media Rights Agenda v. Nigeria para 54. 5 1 Communication 212/98 - Amnestlj International v Zambia" ~¥°'a 54. ~ '-,, 52 Communication 297/05 - Scaulen & Holderness v Zimba ,· g'par l ~ ~ :. ~ 53 Application 004/2013 - Konn.le v. Burkina F(l5o para 12. \ ~ 0 49 .~ i \..2) ' ~ , .,. 0 \ • A f' AU ·U A ~ ") ' . <,..r/o...,"l•Rrc.M''' . ",;:-·v',"' ~ 'TQ ·.,_ . ,~ ,\,/r,11; E1 ut'=• <>'< ~ --~--- a 31 I P a g e

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