reparation has to be fair, adequate, effective, sufficient, appropriate, satisfactory to the victim and proportionate to the damage suffered.44 Release 136. From the arguments developed above, it appears that the judicial authorities of the Respondent State ignored the authority of the judgment of the High Court by using schemes to prevent its implementation. The subsequent measures taken to keep the Complainant in detention also violate the said ruling as well as the procedure of the appeal. In any event, the detention became arbitrary notwithstanding any subsequent action which may have derived concerning the same facts and on the basis of the same charges. Under such circumstances, it is necessary to demand the release of the Complainant pending the outcome of any other ongoing proceedings. Sanctioning perpetrators of the violations 137. The Commission has clearly established the violation of a number of rights relating to fair trial and liberty of the human person. It appears that the administrative and judicial authorities took measures which led to these violations. The Commission is of the view that it is necessary to sanction the perpetrators in order to prevent a recurrence of the established violations. The Commission will thus proceed to consider the related requests. Reparation See Loayza Tamayo v. Peru (1998), Velasquez (1989), Aloeboetoe v. Suriname (1993) of the Inter-American Court of Human Rights; Djot Bayi v. Nigeria (2009) of the ECOWAS Court of Justice. Also see, in general, REDRESS Reaching for justice: The Right to Reparation in the African Human Rights System (2013). 44 40

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