crowd of protesters, such dispersal must be done with reasonable force. Where the Respondent State’s action is to apply sanctions, such sanctions must be applied proportionally to the harm caused. 217. Key to the interpretation of the right to freedom of assembly is the Principle of Limited Sanctions, clearly enshrined in Principle 8 of the Commission’s Guideline on the Right to Freedom of Association and Assembly, which is to the effect that: “Sanctions imposed by States in the context of associations and assemblies shall be strictly proportionate to the gravity of the harm in question and applied only as a matter of last resort and to the least extent necessary.”73 218. The Commission finds that using extreme force on protesters to the extent of causing injuries to many and others dying in the process cannot be termed proportionate. Also, shooting at protesters to disperse them crosses the threshold of proportionality. Arresting and detaining opposition leaders without any lawful cause does not satisfy any legitimate aim and is not in line with practices necessary in a democratic society. 219. The Commission also notes the Respondent State's argument concerning the lack of specific details, such as time, place, and the number of individuals arrested while exercising the right to freedom of assembly, as alleged by the Complainants. 220. The Commission, however, observes that, while asserting the violation of Article 11 of the Charter, the Complainants did cite several incidents in which numerous protesters were claimed to have been arrested, injured, and, in one instance, killed. This information is corroborated by details regarding the locations, dates, and the number of protesters arrested and deceased.74 73 Principle 8, Guidelines on Freedom of Association and Assembly in Africa. 74 In paragraph 48 of their submission, the Complainants submit that in March 2014 seven female and three male party members of the newly formed Semayawi Party (“Blue Party”) were arrested for chanting political slogans that demanded political freedom during a run in honor of International Women’s Day. In paragraph 49 the Complainants allege that in April and May of 2014, protesters in town in the Oromia region were fired at by security personnel for demonstrating against the planned expansion of Addis Ababa’s municipal boundary into the Oromia region. In the same paragraph the Complainants allege that during protests in at least four university campuses in the Oromia region at least thirty bystanders and protesters were killed due to the excessive force displayed by the security force. And in paragraph 50, the Complainants allege that in July 2014, protests from the members of Ethiopia’s Muslim community were arrested for demonstrating for the continued detention of 17 Muslim leaders in 2012. ~ 43 ~ African Commission on Human and Peoples’ Rights 31 Bijilo Annex Layout, Kombo North District, West Coast Region, The Gambia, Phone: (220) 230 4361 Fax: (220) 441 05 04 Email: au-banjul@africa-union.org https:/achpr.au.int/