committed gender-specific violations against the Victims. Failure to investigate effectively, with an outcome that will bring the perpetrators to justice, shows lack of commitment to take appropriate action by the State, especially when this lack of commitment is buttressed by excuses such as lack of sufficient information to carry out a proper investigation. Furthermore, failure to investigate compromises an international responsibility on the part of the Respondent State, both in the case of AC HP R crimes committed by agents of the State and those committed by private individuals. 164. The effects of the violations perpetrated on the Victims were palpable physically, and even from the medical records. The State did not therefore need further information to proceed with the necessary investigation that will bring the perpetrators to justice. As the Inter-American Commission said in Maria da Penha and Maia Fernandes v. Brazil, and this Commission agrees, that “Ineffective judicial action, impunity, and the inability of victims to obtain compensation provide an example of the lack of commitment to take appropriate action…”51 165. The African Commission also holds the same view with the CEDAW which held that, violence against women affects, compromises or destroys the enjoyment and exercise by women of their fundamental and human rights in different spheres of life.52 In this regard, the African Commission considers violence against women as a form of discrimination against them. 51 n 49 above, para. 57 52 The United Nations Committee on Civil and Political Rights 47

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