ACHPR African Commission on Human and Peoples' Rights Human nights our Collective Responsibility spouses, children, fathers and mothers of the deceased'"? , who appear in the final decision as indirect victims. 181. The Commission notes that in this case, the direct victim is Mr Berhane Abrehe Kidane; the indirect victims are his wife and the children, y any. Although the complainants alluded to the detention of the victim's wife in their observations on the merits, the Commission considers that she cannot be included in this case at this stage of the proceedings. However, she benefits from the right to reparations for moral damage in her 9u~a£ityas wife, not as a victim. ,{~::v'-:~.~. _:.;3 ii) On Moral Damages and the Causal Link 182. The Commission notes that the Complainants do:not spe~i(y the amount of monetary compensation sought for non-material damage. They simply ask the Commission to order appropriate reparations. The Commission shares the view of the African Court on the issue of moral damages and th~ir causal link. It should be noted that the African Court's position was inspired by the case law of its Inter-American counterpart'v . In Zongo v. Burkina Faso, the African Court states that: As regards the causal link between the unlawful act and the non-material damage suffered, the Court considers that such a link may arise from the violation of a human right, as an automatic consequence, without the need for any,proof.91 Beneficiaries of the late Norbert Zongo, Abdoulaye Nikiema alias Ablasse, Ernest Zongo, Blaise Ilboudo and Mouvementburkinabe des droits de l'homme et des peuples v Burkina Faso (Reparations) (2015) 1 AfCLR 258, § 5m 90 IACHR: Caracazo v. Venezuela, Judgment of 29 August 2002. Reparations and Costs, paragraph 50 ... "the presumption that human rights violations and a situation of impunity in relation to such violations cause grief, anguish and sorrow, both to the victims and to their relatives. See in this regard Idem: Aloeboetoe v. Suriname, (Reparations and Costs), judgment of 10 September 1993, paragraph 76: Idern l Loayza Tamayo v. Peru (Reparations and Costs), Judgment of 27 November 1998, para. 140: Idem: Gonzalez Medina and Others v. Dominican Republic, 27 February 2012 (Preliminary Objections, Merits, Reparations and Costs), para. 270; Idem: Myrna Mack v. Guatemala, Judgment of 25 November 2003 (Merits, Reparations and Costs), para. 243; IACHR: Mapiripan Massacre v. Colombia, (Merits, Reparations and Costs), Judgment of 15 September 2005, para. 146' "Beyond the above, in a case such .~ ~{,1;lI iUl·'AN as the Mapiripan massacre, the Court considers that no evidence is necessary to show,theJse~Rlfl'ti,wpaf,t on the mental and emotional well-being of the victims' relatives. . .: ':> _ • r '\ 91 Beneficiaries of the late Norbert Zongo, Abdoulaye Nikiema alias Ablasse, I~hest z6rtgo) B ise \, I1boudo and Mouvement burkinabe des droits de l'homme et des peuples v Bur~~ Fa (R:'p~r~lion Lu ~: (2015) 1 AfCLR 258, § 55. I~ <3 ~=.~j( ~ f \ ..l:. ::r: 89 \'i \, -:? AnO"J"'~Oflh. '. Afnqan ((~~ Union ~f~ . t-; AU-UA ~ (.;! .~~.9~i~s' The African CommiSSiO~O? ~~b'tt)f,n , Rights 31 Bijilo Annex Layout. Kombo ~~m)~jstrlt!f.WeslGo't.ist Region Phone: (220) 235.4'261fTf!a.X:'(.220) 441 0504 -r- ~t..-, _..- Email: a u-ba niul(al'clfrica-union.ore: https:/achpr,au,inIfCi 0 D