PART C: Protection against Torture: Procedures before the African Commission and African Human Rights Court one year imprisonment, the complainant, alleging the conviction was in breach of his right to freedom of expression, requested provisional measures in the form of his immediate release and to be provided with adequate medical care in detention. The Court declined to request his immediate release, as this would impact on the substantive case; however, the Court ordered the State to immediately provide him with medication and health care for the entire period of his detention.435 The sub-regional bodies are also empowered to grant interim measures, and have greater flexibility to do so as these are not limited to the prevention of ‘irreparable harm’ as is the case for the African Commission and Court. Under Article 20 of the Protocol on the Community Court of Justice, the ECOWAS Community Court of Justice is empowered to order provisional measures or issue any provisional instructions which it may consider necessary or desirable.436 The EAC Court of Justice may issue interim measures, which have the same effect as decisions of the Court, under Article 39 of the Treaty establishing the Court.437 Under Article 28 of the SADC Protocol on Tribunal, the SADC Tribunal may ‘on good cause, order the suspension of an alleged act challenged before the Tribunal and may take other interim measures as necessary’.438 In the highly contested case of Mike Campbell (Pvt) Ltd and Another v. Zimbabwe, in which the applicants were challenging the acquisition of agricultural land by the Government of Zimbabwe, the SADC Tribunal granted interim measures to halt the removal of the applicants from their land until the determination of their complaint.439 6. Amicable Settlement The Rules of Procedure of the African Commission outline the process for amicable settlements for inter-State complaints and individual communications. respectively. Under Rule 109, the Commission may, at the request of the parties concerned or on its own initiative with the parties’ consent, provide services for an amicable settlement, including facilitating negotiations between the parties as well as ensuring that any amicable settlements reached comply with the provisions of the Charter, that the victims involved have consented to the terms, and that the settlements include an undertaking by the parties for implementation of the terms of the settlement.440 The Commission is also mandated to prepare a report 435 African Court, Lohe Issa Konate v. Burkina Faso, Application No. 004/2013, Order of Provisional Measures, paras. 20 and 22. 436 Protocol on the ECOWAS Court of Justice, Article 20. 437 EAC Treaty (as amended in December 2006 and August 2007), Article 39. 438 SADCT Protocol, Article 28. 439 SADCT, Mike Campbell (Pvt) Limited and Another v Zimbabwe, Case No. SADC (T) 2/2007 (13 December 2007). 440 ACHPR, Rules of Procedure, supra note. 43, Rule 109. 103