steps to provide the victims with reparation.”578 However, the African Commission appears to interpret this standard more strictly than the international instances from which it drew inspiration. It explicitly stated that “[i]ndividual cases of policy failure or sporadic incidents of non-­punishment would not meet the standard to warrant international action;” rather, it considered that a State can be held complicit only in case of systematic failure to provide protection against violations by private actors.579 – Protocol on the Rights of Women The Protocol to the ACHPR on the Rights of Women in Africa (Protocol on the Rights of Women) requires that States Parties protect women against all forms of violence, which it defines as “all acts perpetrated against women which cause or could cause them physical, sexual, psychological, and economic harm, including the threat to take such acts; or to undertake the imposition of arbitrary restrictions on or deprivation of fundamental freedoms in private or public life…”581 The level of State responsibility for ill-treatment by private actors is therefore greater under the Protocol than under the Charter as interpreted by the Commission in Zimbabwe Human Rights NGO Forum v Zimbabwe. 4 The AFrican Regional System In Zimbabwe Human Rights NGO Forum v Zimbabwe, the Commission found that, as the State had investigated allegations of torture brought to its attention, and the complainant had not adduced evidence to show that State organs were responsible for or had acquiesced in specific acts of violence, there was no violation of Articles 1 or 5 as regards violence perpetrated by non-State actors,580 although a violation of Article 1 was found on other grounds. States Parties should include information on legislative and other measures taken to ensure protection of women, including women in detention, against violence in their reports to the African Commission.582 The new African Court on Human and Peoples’ Rights has competence to interpret the Protocol.583 Zimbabwe Human Rights NGO Forum v Zimbabwe (2006), op. cit., §143, footnote omitted. Ibid. §§159–160. 580 Ibid. §§164, 183. 581 Article 1(j) Protocol on the Rights of Women. 582 Article 26 Protocol on the Rights of Women, read in conjunction with Articles 3, 4, 5 and 11. 583 Article 27 Protocol on the Rights of Women. 578 579 131