ffilrta a the appropriate compensation is pecuniary compensation; and this is the solution : chosen by the Court in the instant case. 11. Article 27(1) of the Protocol to the Charter on the Establishment of an African Court cn Human and Peoples' Rights (hereinafter referred to as "the protocoi") states that. "/f the Court finds that there has been viotation of a human or peoples, rights, it shall make appropriate orders to remedy the violation, including the payment of fair compensation or reparation". lt is clear from that article that the Court has full discretion to determine measures of reparation such that can "remedy the situation,,. o o 12. Compared with similar Articles of the European Convention (Article 41) and the lnter-American Convention (Article 63 S 1), the afore-cited Article 27 of the protocol is rather generous and is very similar to Article 61 of the lnter-American Conventionll. As we indicated earlier, Article 41 of the European Convention does not confer on the European Court of Human Rights the possibility of pronouncing 'Just satisfaction" save where "the domestic law allows for the erasure of the consequences of a violation and, even in such a case, only " if it is necessary " to do so. ln other words, the award of just satisfaction does not flow automatically from the finding by the European Court of Human Rights that there has been a violation of a right guaranteed by the European Convention on Human Rights. For this reason, the European Court very rarely pronounced an Applicant's release. ln contrast, Article 63(1) of the lnter-American Convention is quite liberal in as much as it states that: "When it recognizes that a right or freedom protected by this Convention has been violated, the Court shall order that the party iniured be granted the enjoyment of the rights or freedoms infringed. lt will also order, where appropriate, the reparation of the consequences of the measure or the situation which gave rise to the violation of the said rights and the payment of fair compensation to the injured party.,, 13. Even if the Protocol does not speak, like the lnter-American Convention, of the possibility for the Court "to order that the injured pafty be guaranteed the enjoyment of the right or freedom violated", Article 27 speaks of "appropriate measures to remedy the violation", which amounts to the same thing. 14- lt is generally accepted in doctrinel2 and in jurisprudence that release or re- opening of proceedings is necessary only where the Court is of the view that there is no proportionality between the full reparation sought and the violation found, especially if it concerns only one aspect of the right to a fair trial which could not, in 11 See in this sense TIGoUJDA (Helen). "The Reparation of Human Rights Violations: the practice of Regional and Universal Bodies"- Audiovisual Library of lnternational Law, http://legal.u n.org/avl/ls/Tigroudja_HR.html# 12 SHELTON (Dinah), Remedies in International Human Rights law, Axford,University presq zna edition, 2009. 5lPage a-