The African Regional System 4 the ACHPR, as this provision “was not intended to cater for situations where persons in need of medical assistance or help are institutionalised.”606 This restrictive interpretation is in marked contrast to the international trend of expansion of the effective protection of all persons deprived of their liberty. As regards more ‘traditional’ categories of detainees, the Commission has recognised the importance of procedural guarantees, finding for example that “states parties to the Charter cannot rely on the political situation existing within their territory or a large number of cases pending before the courts to justify excessive delay” in bringing the accused before a judge.607 There is no jurisprudence of the African Commission specifically dealing with training of personnel, although the Robben Island Guidelines provide that States should “[d]evise, promote and support codes of conduct and ethics and develop training tools for law enforcement and security personnel, and other relevant officials in contact with persons deprived of their liberty such as lawyers and medical personnel.”608 The Commission has included training of various State officials on human rights issues in general in its programme of activities, but has not specifically stated that training against torture forms part of States’ obligations under the ACHPR. 4.2.6 Duty to grant redress and compensate victims The Commission interprets States Parties’ undertakings under Article 1 of the ACHPR as requiring that effective and enforceable remedies be available to individuals in cases of violations. States are under an obligation to respect, protect and fulfil the human rights of all persons on their territory. As the Commission noted in Zimbabwe Human Rights NGO Forum v Zimbabwe, “To fulfil the rights means that any person whose rights are violated would have an effective remedy as rights without remedies have little value.”609 The Robben Island Guidelines indicate the extent of this obligation; it exists independently of whether a criminal prosecution has or can be brought, extends to victims and their dependents, and covers medical care, social and medical rehabilitation, compensation and support.610 Purohit and Moore v The Gambia (2003), op. cit., §68. Article 19 v Eritrea, AfrCommHPR, Communication No. 275/2003, 41st session, 16–30 May 2007, §99. 608 The Robben Island Guidelines, op. cit., §46. 609 Zimbabwe Human Rights NGO Forum v Zimbabwe (2006), op. cit., §171. 610 The Robben Island Guidelines, op. cit., §50. 606 607 136