270 Mizan Law Review Vol. 6 No.2, December 2012 Claims Commission was mandated ‘to decide through binding arbitration’197 and the Claims Commission was required to use the 1992 Permanent Court of Arbitration Optional Rules.198 Moreover, the Claims Commission is temporary,199 while subregional courts are permanent. The other point stressed by the African Commission is a duty of a court or a tribunal to apply rules of international law to be within the purview of Article 56(7). Obviously, subregional courts have the duty to apply rules of international law. As international treaties constitute one of the primary sources of international law,200 subregional courts are empowered to adjudicate on international treaties.201 For example, in developing its own jurisprudence, the SADC Tribunal has expressly stated that it should have ‘regard to applicable treaties, general principles and rules of public international law and any rules and principles of the law of States.’202 In Campbell the SADC Tribunal referred to several international treaties including the UN Charter while the ECOWAS Court of Justice based its decision on several international human rights treaties.203 Subregional courts, albeit few, also have a human rights mandate while the Claims Commission did not have clear human rights mandate. Subregional courts are more likely to deal with human rights cases than the Claims Commission. Moreover, the number of state parties to the treaties establishing subregional courts is greater than that of the parties to the Algiers agreement, if numbers matter at all. Thus, subregional courts are envisaged under Article 56(7) of the African Charter. 3.6. Textual Interpretation of the African Charter The text of the African Charter could be interpreted to include subregional courts. Article 56(7) of the African Charter provides: Communications relating to human and peoples' rights ... shall be considered if they. [d]o not deal with cases which have been settled by the states involved in accordance with ... [the Constitutive Act of the African Union] or the provisions of the present Charter. 197 Ibid, Art 5(1) & (2). Art 5(7). 199 Ibid, Art 5(8) & (12). 200 Art 38(1)(a) of Statute of International Court of Justice. 201 See Art 27(1) of Treaty Establishing East African Economic Community; Art 16(1) of Consolidated Text of the Treaty of the Southern African Development Community, as Amended. 202 Art 21(b) of SADC Protocol on the Tribunal and Rules of Procedure Thereof. 203 Campbell case, supra note 75; Manneh case, supra note 22; Koraou case, supra note 25; SERAP case, supra note 37. 198 Ibid,