PART 2: Procedures of the Human Rights Commitee and the Committee against Torture are to examine and publicly report on human rights situations in specific countries or territories or on major phenomena of human rights violations worldwide, do not constitute a procedure of international investigation or settlement within the meaning of article 5, paragraph 2(a), of the Optional Protocol.184 The HRC has held that the words, “the same matter”, in Article 5(2)(a) of the OP, have “to be understood as including the same claim concerning the same individual, submitted by him or someone else who has the standing to act on his behalf before the other international body”.185 For example, in Unn et al. v. Norway, a complaint about the same matter (compulsory religious education in Norwegian schools) was submitted to both the HRC and the European Court of Human Rights. However, the complaints were submitted by different sets of parents and students, so the complaints did not concern “the same matter”.186 In Millán Sequeira v. Uruguay, a case had been put before the Inter-American Commission on Human Rights relating to hundreds of persons detained in Uruguay; two sentences of that complaint related to the victim in the OP complaint. The HRC held that the OP complaint was not comparable as it described the victim’s personal complaint in detail.187 Therefore, the two cases did not relate to the same matter. The case will also be rendered admissible if the complaint being examined by another international contentious body was lodged by an unrelated third party, acting without the knowledge and consent of the alleged victim (who is, in turn, the author of the complaint to the HRC). For instance, in Akwanga v. Cameroon the same matter was pending before the African Commission on Human and Peoples’ Rights. However, the author claimed that he never authorized anybody to submit a complaint on his behalf to this body. The HRC, in absence of any documentation from the State party refuting the author’s claim, concluded that the case was admissible.188 As noted above, Article 5(2)(a) does not preclude the admissibility of a case if a case has been considered under an alternative international complaints mechanism, so long as that consideration is completed. However, numerous European States have entered reservations189 to the OP to preclude consideration of cases if they have been previously examined or considered under the European Convention 184 See, inter alia, HRC: Benali v. Libya, Comm. No. 1805/2008, para. 5.2; Sahli v. Algeria, Comm. No. 341/2008, para. 7.2; Djebrouni v. Algeria, Comm. No. 1781/2008, para. 7.2; Laureano v. Peru, Comm. No. 540/1993, para. 7.1. 185 HRC, Fanali v. Italy, Comm. No. 75/1980, para. 7.2. 186 HRC, Unn et al. v. Norway, Comm. No. 1155/2003, para. 13.3. 187 HRC, Millán Sequeira v. Uruguay, Comm. No. 6/1977, para. 9. 188 HRC, Akwanga v. Cameroon, Comm. No. 1813/2008, para. 6.2. See also HRC, Miguel Angel.Estrella v. Uruguay, Comm. No. 74/1980, para. 4.3. 189 A reservation, which must be entered upon ratification of a treaty, modifies a State’s obligations under a relevant treaty. It normally constitutes an intention to opt out of certain provisions of a treaty. 73