50. The Commission further notes that in this case, the Communication has been brought by citizens of a State Party who are rights holders within it and against a State Party to the African Charter. Furthermore, the Communication was brought in respect of violations that allegedly occurred within the territory of the Respondent State, the Republic of Kenya. The Complainant alleges the violation, on the territory of the Respondent State, of rights listed above and protected by the African Charter. The Commission also notes that the African Charter was in force in Kenya at the time of the events. To that extent, the Commission finds that the requirements ratione personae, loci and temporis have been satisfied. 51. Consequently, the Commission concludes that the Communication provisions of Article 56(2) of the African Charter. complies with the 52. Article 56(3) of the African Charter provides that Communications shofifd not be written in disparaging or insulting language directed against the State concerned and its institutions or to the AU. 53. The Commission is of the view that the. essence of Article 56 (3) of the African Charter is to discourage use of language that se~erely damages, without reasonable grounds, the standing of the State or its institutions as the ifirst point of,call for seeking redress, in light of the consideration that the State, as elaborated in SERAC vNigeriat-, bears the primary duty to respect, protect, promote and fulfil the rights enshrined in the African Charter. 54. The Commission notes that Article 56(3) of the African Charter has the additional purpose of safeguarding the integrity of the Communications procedure by ensuring a minimum standard that should be observed in the nature of language used. The Commission thus opines that it is important for parties to respect 'a minimum level of civil discourse. In this regard, the Commission has stated before that for language to be deemed disparaging or insulting, it must clearly go beyond advancing a complaint and intend to bring an institution or officer or the State into disrepute. The European Court of Human Rights (the European Court), in Apinis v Latvia's, stated that language is considered as insulting when it reaches a '~lf?'Pel which exceeds the bounds of normal criticism'. In such circumstances, the European Court may deem a complaint inadmissible for abuse of the right to application. 55. Although the Complainant's submission does not address its compliance with Article 56(3) of the African Charter, the Commission observes that the Complainant uses certain words as articulated hereunder and will analyze those words to determine whether they constitute disparaging or insulting language as envisaged under Article 56(3) of the African Charter.