courts’ orders and undermining the independence of the courts, the Respondent State has violated Articles 7 and 26 of the African Charter. Alleged violation of Article 8 302. The Complainants allege a violation of Article 8 of the African Charter. 303. Article 8 of the Charter guarantees freedom of conscience, the profession and free practice of religion. Article 8 further states that no one may, subject to law and order, be submitted to measures restricting the exercise of these freedoms. 304. The Complainants submit that the handcuffs and blindfolds used on the Victim for prolonged periods left the latter unable to perform ablutions and other religious traditions in violation of Article 8 of the Charter. The Complainants also allege that the guards sought to distress and incite the Victim by destroying pages or verses from the Holy Qu’ran in front of him, and once violently pulling him from the ground in the midst of his prayers. The Commission notes that the Respondent State has not addressed these allegations. 305. “The freedom to practice one’s religion entails all outward manifestations or observance of religious faith or belief, privately or in community with others. An act of practice or manifestation of a religion is one that in the adherent’s perception is required or prescribed by the precepts of the religion that form part of the belief freely held in the forum internum.”111 306. The Commission notes that “one of the pillars of Islam is that Muslims pray five times a day. Before those prayers, they are expected to perform a purification ritual called Wudu [or ablution], requiring that they wash their faces, hands, arms, and feet.”112 The Commission finds that the use of handcuffs and blindfolds on the Victim for prolonged periods would have made it impossible for the Victim to perform ablution. 307. The Commission observes that the right to free practice of religion is subject to law and order. The Commission recalls that in Nigeria Constitutional Rights Project v Nigeria, it stated that the justification of limitations must be strictly proportionate with and absolutely necessary for the advantages which follow.113 308. The Commission has already found that the prolonged use of handcuffs and blindfolds constitutes a violation of Article 5. It is therefore unnecessary for the Commission to analyse the lawfulness or necessity of the restriction. 309. In Amnesty International and others v. Sudan, the Commission held that the government failed to respond in any convincing manner to the allegations made against it and cases where the government does not respond on allegations of Hossam Ezzat & Rania Enayet v. Egypt (n 13 above), para 132. PBS Wudu: Islamic Washing Before Prayer 25 November 2016, available at https://www.pbs.org/wnet/religionandethics/2016/11/23/february-12-2016-wudu-islamicwashing-prayer/29054/. 113 Communications 140/94-141/94-145/95- Constitutional Rights Project and others v. Nigeria (1999) paras 41, 42. 111 112 50