cannot undermine her right established in the past and through a procedure that was validated by the Respondent State itself. 102. The Complainant submits that the Respondent State cannot claim the failure to seek remedies to justify its failure to meet its obligation to protect. She contends that despite the several steps she took to obtain the protection of the State, the latter did not take any measure and was incapable of detecting the numerous cases of error, fraud and irregularities involved in the procedure for issuing the land certificate. The Complainant points out that under Cameroon criminal law the State should have taken action, simply on the basis of information provided to the State Counsel, against third parties and government employees. 103. Regarding the procedure for issuing the land certificate, the Complainant maintains that the State should have annulled the land certificate no. 25641 used by Mr MBAGOFA to claim ownership over the entire land from which was extracted the plot of land allocated to her vendor by the authorities of the Respondent State. In this regard, the Complainant presents correspondences and a report dated November 2008 and January 2009, documents recommending the annulment of the three land certificates mentioned above. The Complainant submits that it is important to find out why the Respondent State failed to discuss these documents. Analysis of the Commission on the Merits Alleged violation of Article 14 104. Article 14 of the African Charter stipulates that: “The right to property shall be guaranteed. It may only be encroached upon in the interest of public need or in the general interest of the community and in accordance with the provisions of appropriate laws”. Using a literal interpretation, the Commission notes that under the said provision the African Charter stipulates a right that is guaranteed but also limited by the interest of public need and general interest, limitations that have to be determined by the relevant laws. 105. After considering the arguments put forward by the parties, it appears to the Commission that in this case, the limitations provided for under Article 14 of the African Charter do not apply; the reason being that in response to the violations alleged by the Complainant the Respondent State does not invoke neither general interest nor public need. In order to determine if the right guaranteed under Article 14 has been violated, the Commission will consider 23