African Charter, this can constitute a violation, even if the state or its agents are not the immediate cause of the violation.” 142. The African Commission also notes its decision in the case of Amnesty International v Sudan, where it stated that “ratification obliges a state to diligently undertake the harmonization of its legislation to the provisions of the ratified instrument.”34 It further stated that “article 1 of the Charter confirms that the government has bound itself legally to respect the rights AC HP R and freedoms enshrined in the Charter and to adopt legislation to give effect to them.”35 143. The African Commission is of the opinion that the existing legislation (at the time of the submissions) in the Respondent State is contrary to the spirit of Article 1 as it does not ensure that there is compensatory damages to give just satisfaction to victims of wrongful death particularly close family and relatives who are bereaved because of such deaths. Decision of the African Commission on Merits 144. In view of the above, the African Commission finds that the Respondent State is in violation of Articles 1 and 4 of the African Charter. Recommendations 145. The African Commission recommends that the Respondent State should: (a) Undertake law reform to bring domestic laws on compensation in case of wrongful killings into conformity with the African Charter and other 34Communication 35 Id, para 42 48/90, 50/91, 89/9, para 40 40

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