Human Rights and Development in Africa v Zimbabtoe" that Article 56 (3) must be interpreted in light of Article 9(2) of the African Charter, which guarantees the right to freedom of expression. A determination of compatibility with Article 56 (3) therefore rests on the balancing of two interests, namely allowing Complainants to present their case as freely as possible and ensuring that Communications do not unnecessarily and without reasonable ground use language that puts into question the standing of a State or its institutions. 44. In Eyob B. Asemie v the Kingdom of Lesothow, the Commission held that "It is also important to note that a Communication alleging human rights violations by its very nature should be expected to contain allegations that reflect negatively on the State and its institutions". Accordingly, allegations that reflect negatively on the State or its institutions, such as allegations of corruption would not by themselves be deemed to constitute disparaging or insulting language, within the meaning of Article 56 (3). 45. The Commission also notes that Article 56(3) 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 considers it important that parties are also expected to respect a minimum level of civil discourse. In this regard, the European Court of Human Rights (European Court), in Apinis v Latoiau, stated that language is considered as insulting when it reaches a 'level 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. The Commission is further of the view that while Complainants may express their emotions on their circumstances or in regard to the specific actions of the respective State, this should not transform into ad hominem attacks on the State or its institutions, thereby exceeding the bounds of normal criticism or reasonable expressions of strong emotions. 46. In this particular instance, the Complainant accuses the Respondent State of "exposing your humble petitioner [the Complainant] and his clients to revenge, retribution and retaliation" for allegedly exposing "wrong doings" during elections for the position of Speaker of the National Assembly in 2003. The Complainant states that in its efforts to punish him, the Respondent State "enlisted the services of the Kenyan judiciarf", In another instance, the Complainant states that his complaints have been treated with "disdain, suspicion and contempt" and that the Respondent ~.tl"i .q erly insulating or shielding recalcitrant judicial officers". He $>"~e§I.:fl\~"If'~·. &e "damning evidence" to describe his submissions to the efun o~ o I" , U " • ~ ..: I! W - ..AJ \ n "7l Communication 293/04- Zimbabwe Lawyers for Human Rights and the Instit(Jf~ ~~ Hu~~tt;Rights 'and Development in Africa v Zimbabwe ~ ~, '/ . 9 10 Communication 435/12 - Eyob B. Asemie v the Kingdom of Lesotho (2015) ~R"p~ara 46549/06 - Gundis Apinis v Latvia (2011) ECHR, para 16. ~/. 11 App 58. ' 10