been adopted at a later date. From the preambular text of the OAU Convention, the Commission observed that the latter is a 'compliment' to the 1951 UN Convention. From that understanding, the Commission stressed that it was enjoined to 'read the provisions of the three instruments as complementing each other' and that the said provisions 'are at most complementary to each other and not mutually exclusive' 25 . Considering that the Maputo Protocol, at the outset, underscores its supplementary or complementary nature vis-avis the Charter, a finding that the Commission may also derive its material jurisdiction under the Protocol within the context of the Charter is in line with its previous approach to the interpretation of complementary instruments. 72. Legal scholarship on this issue leans tcn,varqs the above finding. The consensus is that the Protocol as a supplement to the African Charter falls under the Commission's contentious jurisdiction. Viljoetl argues that "as a substantive rather than a procedural supplemeI).t, the protocol is ~uperimposed on the existing protective framework of the Commissicm". He argues further that "the logic of the complementarity relationship between the African Charter and the [Maputo Protocol] requires that the Protocol be read as enlarging the scope of claims that maybe su'b mitted to the Commission in order to improve the situation ofwo:rilen'i. He thus concludes that "in the absence of any explicit provision excluding the competence of the'Commission to do so, the Protocol should be understood to mandate the Commission to examine Communications alleging violations of the rights under the Protocol 11 26 . 73. Similarly, in the CoHon field 27 case, concerning the State's failure to investigate the homicides of three women in Mexico in the context of mass gender violence, the Inter-American Court' sought to determine its material jurisdiction over the Inter-American Convention on the Prevention, Punishment, and Eradication of Violence Against v\Tomen (IAW /Convention of Belem do Para) 28 . There, the State objected to the Court's jurisdiction citing in particular Article 12 of the IAW which refers ' exclusively to the lodging of petitions before the InterAmerican Commission. The State argued that by excluding the Court, the IAW prohibited the exercise of the Court's contentious jurisdiction. 74. The Inter-American Court rejected the above submissions. The Court held that Article 12 of the IAW, when interpreted with reference to the provisions of the American Convention permitted the exercise of its jurisdiction29 . The Court reasoned that the provision in Article 12 which enjoined the Inter-American Commission to " ... consider such claims [under the IAW] in accordance with