p.CHP.lf ( ~ f) 6~!:j,Efi Human R,ghts ou, Human and Peoples' Rights Collective Responsibility and Development in Africa v. Zimbabwe6, the Commission determines that, in order to consider language to contain abusive or insulting vocabulary, Complainants must have a clear reason and intent to effectively contempt the institutions of the State and therefore humiliate its judiciary or even its political sovereignty. 62.As demonstrated above, the Commission, in setting the threshold, set the bar high, even though it acknowledged that in certain cases, certain language, which may appear derogatory or insulting, could simply be interpreted as the very expression of the complainants' opinion. In the case of Eyob B. Asemie v. the Kingdom of Lesotho 7, the Commission stated that, despite the language used, which may have been interpreted as tarnishing the image of the institution, the Complainants merely expressed their opinion and perception of it. 63. In order to carry out a rigorous analysis of the language used in the complaint under consideration, a comparative exercise may be useful, as it may demonstrate the extent to which the threshold can be breached beyond what can be considered freedom of expression. In the case of Uhuru Kenyatta and William Rufo (represented by Innocence Project Africa) v. Republic of KenyaB, the Complainants referred to the institutions and the regime as "disgusting", "shampuppet", "demonisation", "fishing expedition". These expressions can be regarded as serious accusations against the Kenyan institutions and may, in the Commission's view, lead to the pollution of the minds of the population. 64. In addition to the Commission, the African Court on Human and Peoples' Rights has an equally well-established case law on the matter. The Court based its decision on the Commission's arguments, thus consolidating its position in both the case of Actions pour la Protection des Oroit de /'Homme (APDH) v. Republic of Cote d'lvoire9 (application 001/2014, Judgment, 18 November 2016, para. 82) and in the case of 6 Cou,munication 294/ 04: Hum•n Rights Lawyers o/ Zimbabwe and Institute for Human Rights and Development in Africa (on behalf of Andrew Barcia)' Meldrum) v. Zimbabwe https://" w w 4ch pr.J1V/puMic/ l111cument/fil,•/Fnelish/ad1preo6 29-t 0~ r ng.pdf 7 Communicc1tion 435/ 12 B, Eyob Asemie v. the Kingdom of Lesotho hup~·//www_jlhpr.ore,/publk/Don1ment/liJ1.:o/bu~Jish /Jl ltpr l(>eos dcds -1'.\5 12 k>solho en~.pdl 8 Communication 464/ 14 Uhur, Kenyatt,1 and Willi<1m Protection des Droil de Rulo (represented by Innocence Project l'l-lomme (APDI-I) v Republic of hllrs://www.i-u·hpr.or:r,/.~ 9 Actions Pour In COte D' I \O\>rl,Qrg/cn/ imagfs /CaSt's /lu~ l x ; \ JF:S:T 1\ PPI .ICA'TION%20001 %202014 %20 ~20A l'Dl 1%2QYJ(,20TI l!f:F.~~2l(!JR IBEf.lPlJ.!lJB1jl.lfm ~ Rf.pd[ ~ rnr~ M u ~ ~ "' - ~ ~ , <:.,,. g'- .ci~~ICAl~t. ~ · ··O-t,~£ O OES ~t,-S -,, -~ .- '{I