internally, after the official investigation was closed. The Commission in Communication 48/90-50/91-52/91-89/93 - Amnesty International, Comité Loosli Bachelard, Lawyers' Committee for Human Rights, Association of Members of the Episcopal Conference of East Africa v. Sudan held that: Constituting a commission of the District Prosecutor and police and security officials […] overlooks the possibility that police and security forces may be implicated in the very massacres they are charged to investigate. This commission of enquiry, in the Commission's view, by its very composition, does not provide the required guarantees of impartiality and independence. 189. Similarly, in the current case, leaving violations as grave as killings to internal investigation, clearly does not provide the required guarantees of impartiality and independence of process. There is also no indication on the side of the State as to any steps which had been taken to undertake such an internal investigation and if it had been done, what the conclusions were and whether such findings had been made public. 190. The Commission thus finds that there was a failure by the State to undertake prompt, impartial, thorough and transparent investigations into the killings. Based on the aforegoing, the Commission therefore finds a violation of Article 4 on the right to life. Analysis of Article 5 191. Article 5 of the African Charter provides that every individual shall have the right to the respect of the dignity inherent in a human being, and to the recognition of his legal status. All forms of exploitation and degradation of man particularly slavery, slave trade, torture, cruel, inhuman or degrading punishment or treatment shall be prohibited. 192. The Complainants submit four arguments to support their submission that the State had violated the human dignity of the Victims and ill-treated them. Firstly, they argue that in the park and during their subsequent detention the Victims were under the control of the State, and suffered physical harm and mental anguish. Secondly, they assert that incommunicado detention can amount to inhuman and degrading treatment per se. Thirdly, they submit that the way in which the State dealt with the bodies of the deceased, including in providing access to the family, release and burial amounted to inhuman and 51