identified. This is more so because the threshold for applying the actio popularis principle has yet to be expounded on by the Commission, which gives room for abuse of the principle by litigants. 63. The present Communication is filed on behalf of the Ethiopian Electorate, and the victims have not been identified. Whereas actio popularis, in its strict sense, does not require the identification of any victim, as it is sufficient that the complaint solely alleges incompatibility of national laws or practices with international law.12 The principle is, therefore, a recognition that the collective damages incurred are so diffused that any person should have the right to litigate in the public's interest.13 In this regard, complaints by NGOs may also be called actio popularis if the NGO does not need to identify or name the victims. 64. According to the Commission’s jurisprudence, the Commission has seized and admitted Communications submitted on the grounds of actio popularis without the requirement of identifying the victims.14 Indeed, the Commission has regularly admitted cases concerning entire populations of individuals, including Legal Resources Foundation v Zambia.15, Kevin Mgwanga Gunme et al. v Cameroon,16 The Nubian Community in Kenya v Kenya,17 and Open Society Justice Initiative v. Côte d’Ivoire.18 65. As stated in paragraphs 3, 4, and 5 of the summary of facts of this Communication, The Respondent State’s systematic crackdown on media, public demonstrations, human rights organizations, and political opponents in the 2015 electoral period unlawfully restricted civic space in the country, including the rights to freedom of assembly, freedom of association, and freedom of expression. Each unlawful restriction to civic space and the broader chilling effect produced by this systematic pattern of repression prevented the free flow of information, public debate, and dialogue from taking place in the 2015 electoral 12 A Aaken “Making international human rights protection more effective: A rational-choice approach to the effectiveness of locus standi provisions” (2005) 16 Max Planck Institute for Research on Collective Goods 1 at 14 https://www.econstor.eu/bitstream/10419/26871/1/50037676X.PDF 13 A Aragao & A Carvalho “Taking access to justice seriously: diffuse interests and actio popularis. Why not?” (2017) 2 Environmental Law Network International 42 at 43 https://www.elni.org/fileadmin/elni/dokumente/Archiv/2017/Heft_2/elni20172_Aragao_etal.pdf 14 n 7 above, para 79. 15 Communication 211/98. 16 Communication 266/03 - Kevin Mgwanga Gunme et al v Cameroon (2009) ACHPR. 17 Communication 317/06. 18 Communication 318/06. ~ 10 ~ African Commission on Human and Peoples’ Rights 31 Bijilo Annex Layout, Kombo North District, West Coast Region, The Gambia, Phone: (220) 230 4361 Fax: (220) 441 05 04 Email: au-banjul@africa-union.org https:/achpr.au.int/