approach asks whether the same judge offered guarantees sufficient to exclude any legitimate doubt of impartiality. 33. In applying the subjective approach to the facts of this case, the Commission observes that the Respondent State attributes bias to the Honourable Commissioner without providing actual proof of her partiality. In every case where bias is imputed, the Commission will presume the existence of impartiality unless proof to the contrary is provided. As noted above, the Commissioner’s participation on the panel in itself is not proof of her partiality as she was well within her mandate. 34. The Commission's mandate is provided for under the African Charter4 and the drafters of the Charter intended that the Commission should carry out all its functions simultaneously. These functions are for the promotion of human and peoples’ rights, the protection of human and peoples’ rights and the interpretation of the Charter. Protection is whereupon the Commission carries out sensitisation, public mobilisation and information dissemination activities through seminars, symposia, conferences and missions.5 The protection of human and peoples’ rights occurs when the Commission exercises its communication procedure, friendly settlement of disputes, state reporting (including consideration of NonGovernmental Organisations’ shadow reports), urgent appeals and other activities of special rapporteurs and working groups and missions.6Article 45 of the African Charter also bestows on the Commission the mandate to interpret provisions of the Charter upon a request by a state party, organs of the AU or individuals. No organ of the AU has referred any case for the interpretation of the Charter to the Commission. However, a handful of NGOs have approached the Commission for interpretation of the various articles of the Charter. The Commission has also adopted many resolutions expounding the provisions of the Charter. 35. These three mandates are complementary and are carried out by the 11 Commissioners appointed in terms of Article 31 of the Charter and exercised in accordance with the Charter and the Rules of Procedure of the Commission as envisaged in Article 42 (2) of the Charter. The Respondent State’s allegation of bias, deriving from the actions taken by a Commissioner in the process of exercising one of the mandates set out in the Charter, cannot be sustained on 4Article 45 of the Charter. Mandate of the Commission, http://www.achpr.org/about/mandate/. 6ACHPR; Mandate of the Commission, http://www.achpr.org/about/mandate/. 5ACHPR;