69. They assert that health services, including maternal health care, should be provided in a manner that respects women's dignity and their right to be free from abuse. When women are abused in the area of reproductive rights, the responsibility of the State is often brought into play through the enforcement of restrictive and discriminatory laws or policies, actions by health professionals who do not respect ethical standards, lack of appropriate regulation of private health facilities, or lack of punishment for violence perpetrated by individuals. 70. The Complainants point out that Article 5 of the African Charter combines a wide range of rights, including the protection of the right to dignity and liberty against ill-treatment. To substantiate their allegations, they refer to the jurisprudence of the African Commission, where the latter explained that this provision is violated when a person is exposed to suffering or treated in an undignified manner and that coercive acts, including the denial of reproductive health services, constitute cruel, inhuman and degrading treatment in violation of Article 5 of the African Charter. 71. The Complainants further point out that the Article 4 of the Maputo Protocol guarantees the right of women to be treated, with dignity. Addressing the issue of detention of pregnant women-in health*iacilities, the Corripjainants contend that States must ensure that women are not treated in an inhumane, cruel, and degrading manner when s,eeking sexual and reproductive health services. They insist that in its mo§t recent, <Epndu~g\ Obse:Vi?tions, the Commission repeatedly expressed concern about violenc~ against women, recommending that Nigeria strengthen its operational and Institutional capacity to address violence against women by ensuring that cases of violence are properly investigated and prosecuted and by raising public awareness. \ v 72. The Cq.B}plaiIlants note that the right to dignity and to non-abuse is also enshrine~ ~n~ri~b~J?er oHnternatiq,nal human rights instruments, all of which Nigeria ha~ ratified' 'The Complainants add that States parties to these instruments,.h~}0~~~.ob~i~~~~nto refrain from committing acts ~f ill-treatment and to take eff~cfivejudicial-and other measures to prevent, pumsh and redress ~" 'h such acts. ;' 73. 13

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