there has been no submission to this effect, the Commission finds that the right to property had been violated and thus finds the State in violation of Article 14. Analysis of Article 16 240. Article 16 of the Charter provides that every individual has the right to enjoy the best attainable state of physical and mental health, and that there is a duty on the State to protect the health of people and ensure that they receive medical attention when they are sick. 241. The Commission in its Guidelines and Principles on Economic, Social and Cultural Rights in the African Charter on Human and Peoples' Rights determines that individuals have the right “to be free from unwarranted interference [with their health], including […] inhuman and degrading treatment”.69 Further, in General Comment No.14 on the right to health, the UN Committee on Economic, Social and Cultural Rights provides that: “[...] the right to health imposes three types of obligations on States – to respect, fulfil and protect the right.” In the Interrights v Egypt case,70 the Commission held that because the Victims had been submitted to acts which resulted in physical and emotional injury, which has detrimentally affected their physical and mental well-being, there is a violation of Article 16 (1). 242. In relation to the duty to respect and protect, the Commission had already found above that the treatment of the protesters resulted in inhuman and degrading treatment. The Commission in addition found above that the State was responsible for the injuries suffered as a result of the removal. The Complainants argue that the right to health can be violated though direct action by the State or others insufficiently regulated by the State which cause positive harm to health. While the Commission considers the police to be part of the State, it finds that the State can be directly held accountable for actions of the police, nevertheless, based on the duty to protect, the State would also have a duty to ensure that third parties do not interfere with the enjoyment of the right to health. Based on the above, the Commission finds that the right to Guidelines and Principles on Economic, Social and Cultural Rights in the African Charter on Human and Peoples' Rights, para 65. 70 Communication 323/06: Egyptian Initiative for Personal Rights and INTERIGHTS v Egypt. 69 68