constant jurisprudence and notes that the language prohibited must be directed against the State Party, its institutions or the African Union. In addition, compliance with this provision is intended to avoid a situation where Communications submitted to the Commission would indicate an intention to undermine the integrity and status of the institution concerned, as well as to discredit it. 52. Thus, in the case of Ilesanmi v. Nigeria, the Commission found that the fact that the Complainant called the President of the Republic “corrupt” and declared that he had “received bribes, kickbacks from drug traffickers” was aimed at ridiculing, discrediting the institution and therefore constitutes the use of disparaging or insulting language. 2 53. However, in the case of Bakweri Lands Claims Committee v. Cameroon,3 the Commission held that the mere fact that the Complainant claimed that “the President of the Republic wielded extraordinary powers so as to influence the judiciary and that the judiciary is partial and lacked independence” cannot be considered insulting. The Commission considered that this is a “mere allegation depicting the Complainant’s comprehension of the functioning of State entities”. 54. In this case, the Commission notes that the language contested by the Respondent State is actually contained in the Complainant’s observations. In paragraph 3 of the submission, it can indeed be read that: “Faced with a largely negative balance sheet, the regime, which has been in power for thirty years, has come up with a hoax to scapegoat a number of senior officials, on the trumped-up charge of misappropriation of State funds, for the sole purpose of gaining credibility in the eyes of international donors.” 2 3 Communication 268/03 (2005) AHRLR 52 (ACHPR 2005) paras 38-40. Communication 260/02 (2004) AHRLR 37 (ACHPR 2004) para 48. 13