195. The Respondent State contends that allegations regarding the deaths of opposition party members are not sufficiently supported with evidence that links deaths to violations of freedom of association. The Respondent State argues that investigations were carried out and perpetrators brought to justice, both for the deaths and arrest of opposition party candidates. 196. The Commission has stated that freedom of association is an individual right, and the State must refrain from interfering with the free formation of associations.58 The right to freedom of association applies to “any group of individual or legal entities brought together to collectively act, express, promote, pursue or defend a field of common interest.”59 197. The Commission emphasizes that associations must be free to pursue various activities, including exercising their rights to freedom of expression and assembly. Additionally, the right to freedom of association also carries with it a duty that obliges States to establish an environment conducive to exercising this right without fear and encumbrances.60 This is also echoed by the Commission’s Report on the Study of Freedom of Association and Assembly, which underscores that States should not interfere with these rights but rather protect associations from others who might seek to interfere with them.61 198. Similarly, the Commission’s Guidelines on Freedom of Association and Assembly require States to respect, in law and practice, the right of associations to carry out their activities without threats, harassment, interference, intimidation, or reprisals of any kind.62 According to the Guidelines, any limitations imposed by States shall be in accordance with the principle of legality, have a legitimate public purpose, and be necessary and a proportionate means of achieving that purpose within a democratic society, as these principles are understood in the light of regional and international human rights law.63 Communication. No. 101/93 - Civil Liberties Organisation v Nigeria, paras 54 to 59. Report of the Special Rapporteur on the right to freedom of peaceful assembly and of association on, Maina Kiai, A/ HRC/20/27, para 51. 60 Report of the Special Rapporteur on rights to freedom of peaceful assembly and association, para 63, U.N. Doc. A/HRC/20/27 (May 21, 2012). See also Guidelines on FoAA, para 28. 61 Report of the Study Group on FoAA. 62 FoAA, Para 9. 63 FoAA, Para 24. 58 59 ~ 38 ~ 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/