Anor5 and the House of Lord’s case of Pepper v. Hart6 to demonstrate the use of the generous and purposive interpretation at the domestic level. 42. The Complainants also submitted that purposive interpretation applies under international pursuant to Article 31(1) of the Vienna Convention on the Law of Treaties (1969). In this regard, they refer to the case of Soering v. United Kingdom7 where the European Court of Human Rights held that all the provisions of the European Convention on Human Rights should be read harmoniously (specifically that Article 3 of the ECHR should be construed in harmony with Article 2), and that the most appropriate interpretation will that which realises the aims and objectives of the treaty. Illustratively, the Complainants also refer to the decisions of the Commission in Media Rights Agenda and Constitutional Rights Project v. Nigeria8, Interights & Others v. Islamic Republic of Mauritania9, Social and Economic Rights Action Center & The Centre for Economic and Social Rights v. NIGERIA10, wherein the Commission has upheld and utilized the purposive and generous interpretation approach even without expressly saying so. 43. The Complainants submit that Article 4 of the African Charter neither expressly permit nor prohibit the death penalty. It protects the right to life without any limitations. The interpretation given to the word ‘arbitrary’ is important. In addition, Article 4 should also be interpreted ‘in accordance’ with Article 5. In this regard, the Complainants submit that the two articles interpreted in a holistic, generous and purposive manner would reveal that ‘the right to life and dignity are inherent to all individuals under the African Charter.’ 1994 TLR 146 (HC) (1993) AC 573 7 11 Eur. Ct. H.R. (ser. A) (1989) 8 Communications 105/93, 124/94 and 152/96 9 Communication 242/2001 10 Communication 155/95 5 6 13 | P a g e