the Complainant is a political entity established by the Muslim Brotherhood, which had been declared a terrorist organization by a ruling of the North Cairo Criminal Court on 1/6/2017; and (3) the Communication is brought by a political party, whereas political parties are not included in the Rules of the Procedure of the Commission under Rule 63 (1) which lists the institutions which may request for a matter to be included in the agenda of the Ordinary Session of the Commission. 64. The Commission has on previous occasions dealt with the matter of locus standi and has established principles DITSHWANELO 5 case)1 (on in this regard. In behalf of Lehlohonolo Commufiication Bernard Kobedi) 277/2003 v. - Spilg and Botswana Mack & (DITSHWANELO the Commission confirmed that neither the African Charter nor the Commission's Rules of Procedure contain specific provisions on locus standi. It therefore held that the only possible applicable provision is Article 56 (1), which "simply requires that the Communication indicate its author(s), even if they would like to remain aponymous. This provision does not specify, which parties Commission."16 The Commission has thus ado have standing before the African tea an exceptionally wide approach to locus standi, which according to the DJTSHWANELO case:17 places no restriction as the conditions under standing before it, to who can bring a Communication before Article 56 of the African Charter are met by has been As long as the person the African Commission will entertain the Communication. The rationale for the Commission's comparative broader approach standi it. associated with the peculiarity to the issue of locus of the African situation, and the perceived generous intent of the African Charter. 65. Finally, the Commission determined that "the through not be a 66. Despite its jurisprudence national this or be permissive that the registered approach, person in the there African or NGO territory are still Commission has filing of made it clear the Communication need the Respondent State" limitations to who .1s may bring Communications before the Commission. One implicit requirement under Article 65 (1) is that th e " author" must be a person, in order to have standing. Thus a Complaint may be brought by either a natural person or a juridical person19. In the present case the 15 Communication 277 /2003 - Spilg and Mack & DITSHWANELO (on behalf of Lehlohonolo Bernard Kobedi) v. Botswana (2013) ACHPR. 16 Communication 277/2003 - Spilg and Mack & DITSHWANELO (on behalf o f Lehlohonolo Bernard Kobedi) v. Botswana (2013) ACHPR paras 73-74. 17 As above, para 81. 18 As above, para 79. r;.1<"Vtl�•�u:i[ 19 Also known as artificial person, juridical entity, juridic person, juristic person, or legal per�' -�f e'f�� ,,\ i \ \;;, � '4. -, '\_ . ....� <, �u-M· I :';II � ff (;) ,., ,., '<"" {SJc�4�.,;,-:,.1:f:¢..$'./ ',.1:_o,� rt ��� � 14