The Admissibility of Subregional Courts’ Decisions before the African Commission. .. 265 Article 56(7) of the African Charter extends the principle of double jeopardy beyond individuals to state parties since it prohibits the African Commission and the African Court from considering a matter that has already been settled. Thus, it establishes the rule ne bis in idem.155 Applied to a state, the rule implies that ‘a state should not be found in violation twice’ for the same action or conduct.156 In Bakweri Land Claims Committee v Cameroon, a communication was brought before the African Commission concerning sale of land owned or used by Bakweri, an indigenous community in Cameroon’s Fako division. The respondent state raised preliminary objection under Article 56(7)157 and argued that the communication was inadmissible as the UN Sub-Commission on the Promotion and Protection of Human Rights had already settled the case.158 While explaining the principle behind the requirement under Article 56(7), the Commission held the following:159 The principle behind the requirement under this provision of the African Charter is to desist from faulting member states twice for the same alleged violations of human rights. This is called the ne bis in idem rule (also known as the principle or prohibition of double jeopardy, deriving from criminal law) and ensures that, in this context, no state may be sued or condemned for the same alleged violation of human rights. In Africa, human rights are expected to be protected at four levels: national, subregional, regional and global.160 The promotion and protection of human rights at subregional, regional and global levels fall within the international protection of human rights.161 Subregional courts are regarded as international courts because they are permanent organs established by international legal instruments and apply international law according to their own rules of procedure on disputes between states or disputes in which one of the parties is a state.162 If the cases that are already tried by subregional courts are admissible to the African Commission or the Court, the defendant states would be tried twice for the same conduct before international tribunals. Therefore, admitting cases 155Viljeon (2007), supra note 1, p. 126. 156Ibid. 157Bakweri Land Claims Committee v Cameroon (2004) AHRLR 43 (ACHPR 2004). 158Ibid, para 38. 159Ibid, para 52. 160 Viljoen (2007), supra note 1, p. 9. Africa has subregional institutions that deal with human rights. 161Ibid. 162 Lucyline Nkata Murungi (2009), ‘Revisiting the role of sub-regional courts in the protection of Human rights in Africa’ unpublished LLM thesis, University of Pretoria, p. 32.