arrested or detained shall be given reasonable facilities to receive visits from family and friends, subject to restriction and supervision only as are necessary in the interests of the administration of justice and of security of the institution.”122 323. Although detention inherently entails limitations, detainees retain the right to family life. Authorities must enable and if need be assist the detainee in maintaining contact with his close family.123 324. The Commission has held that “[e]nsuring protection of the family also requires that States refrain from any action that will affect the family unit, including arbitrary separation of family members […].” Therefore, incommunicado, arbitrary, or unlawful detention, in violation of Article 6 of the African Charter, constitutes arbitrary and unlawful interference with the family unit. In Constitutional Rights Project and Civil Liberties Organisation v. Nigeria, the Commission held that by holding the Victims in incommunicado detention, the State violated Articles 6, 7, and 18 of the African Charter.124 325. Additionally, the Commission has held that “[b]eing deprived of the right to see one’s family is a psychological trauma difficult to justify, and may constitute inhuman treatment.”125 In Law Ghazi Suleiman v. Sudan, the Commission held that “detaining individuals without allowing them contact with their families and refusing to inform their families of the fact and place of the detention of these individuals amounts to inhuman treatment both for the detainees and their families.”126 The Istanbul Protocol also lists the deprivation of social contacts and loss of contact with the outside world, as a method of torture.127 326. The Respondent State does not address the Complainant’s allegations with regards to the State’s interferences with the Victim’s right to family life. In the absence of contrary arguments, the Commission will accept the allegations as facts. 327. The Commission has found that the Respondent State violated Articles 6 and 7 by arbitrarily and unlawfully detaining the Victim, and denying his right to fair trial. The Commission therefore finds that the Respondent State arbitrarily and unlawfully interfered with the Victim’s family unit. Furthermore, by unlawfully restricting the Victim’s right to family life, the State has also violated Article 5, also failing to uphold one of the basic procedural safeguards against torture.128 Alleged violation of Article 1 328. The Complainants allege a violation of Article 1 in conjunction with the other articles allegedly violated by the Respondent State, particularly because the State failed to provide compensation or rehabilitation for the violations the Victim has 122 Principles and Guidelines on the Right to Fair Trial, M(2)(g). Piechowicz v Poland (2012) ECHR (Application No. 20071/07) para 212. 124 Constitutional Rights Project and Civil Liberties Organisation v. Nigeria (n 90 above), para 28 – 29. 125 Communication 151/96 – Civil Liberties Organisation v. Nigeria, (1999) ACHPR para 27. 126 Law Office of Ghazi Suleiman v Sudan (n 7 above), para 44. 127 Istanbul Protocol, para 145 (n). 128 Robben Island Guidelines, Guideline 20 (a). 123 53