Cameroon,30 the African Commission also held that averments such as “Paul Biya must respond to crimes against humanity", "30 years of the criminal neocolonial regime incarnated by the duo Ahidjo/Biya", "regime of torturers", and "government barbarisms"31 as insulting language. 103. However, in Bakweri Land Claims Committee v. Cameroon32 the African Commission held that the use of strong language such as “no judge… will risk AC HP R his/her career, not to mention his/her life, to handle this politically sensitive matter…” per se will not amount to disparaging and insulting language.33 104. After a careful examination of the tone of the language used in presenting the Communication, the African Commission is satisfied that the Complainants have met the requirements under Article 56(3) of the African Charter. 105. Article 56(4) of the African Charter requires that any Communication brought pursuant to Article 55 of the African Charter will be considered if the facts are not based exclusively on information from the mass media. This requires that the Complainants must proof that, the evidence of the facts constituting the alleged violations, are not based exclusively on information from the mass media. While conceding that there is a single reference to news obtained from the mass media, the Complainants have argued that this Communication is based on primary evidence within the knowledge of the Complainants. 106. In the case of Sir Dawda K Jawara v. Gambia34 the African Commission held that while it will be dangerous to rely exclusively on news disseminated through the mass media, it would be equally damaging if the African Commission were 30 Communication 65/92, (ACHPR) 10th Activity Report Ibid, Para. 18 32 Communication 260/02 (AHRLR) 2004, 43. 33 Ibid, Para. 48 34 Communication 149/96, (ACHPR) 13th Activity Report 31 25