Quels recours pour les victimes de la torture ? Guide sur les mécanismes de communications individuelles des organes de traités des Nations Unies concerned’concerned’. However, the Court does not appear to have done so in its thus far limited jurisprudence. The sub-regional bodies are also empowered to consider and rely on international law. Article 21(b) of the Protocol on the SADC Tribunal provides that the Tribunal shall develop its own jurisprudence, ‘having regard to applicable treaties, general principles and rules of public international law’.488 In United Republic of Tanzania v. Cimexpan (Mauritius) Ltd, the SADC Tribunal defined torture by reference to the definition found in Article 1 of the UN Convention Against Torture.489 12. Remedy and Reparation It is difficult to neatly delineate the remedies issued by the Commission. In the evolution of the Commission’s practice, three approaches to remedies may be identified. First, during its earliest years, the Commission for the most part simply found a violation and refrained from making any statement about possible remedies. The root of this reticence lay in the fact that neither the Charter nor the Commission Rules of Procedure make mention of remedies. Second, the Commission later began to adopt vaguely formulated remedies, such as the recommendation that the State should ‘take the necessary steps to bring its law into conformity with the Charter’. Third, the Commission sometimes recommends more detailed and direct remedies, such as an appeal to the State Party ‘to permit the accused persons to a civil trial with full access to lawyers of their choice; and to improve their conditions of detention’. However, the Commission’s practice has remained inconsistent. As a result, there are significant gaps between the practice of the Commission with regard to awarding reparation to victims of human rights violations, and international standards for reparation, including those found in the UN Basic Principles and Guidelines on the Right to a Remedy and Reparation for Gross Violations of International Human Rights Law and Serious Violations of International Humanitarian Law.490 Over the years, the Commission has taken each approach described above in Article 5 cases. In Rights International v. Nigeria,491 as well as in the Huri-Laws case,492 for example, the Commission found Article 5 violations, but did not offer recommended remedies. The remedy recommended in OMCT et al. v. Rwanda,493 following a violation of Article 5 as well as other provisions, is couched in an open-ended 488 SADCT Protocol, supra note 130, Article 21(b). 489 SADCT, United Republic of Tanzania v. Cimexpan (Mauritius) LTD and Others, Case No. SADC (T) 01/2009. 490 REDRESS Report, “Reaching for Justice: The Right to Reparation in the African System” (October 2013). 491 ACHPR, Rights International v. Nigeria, Comm. No. 215/98. 492 ACHPR, Huri-Laws v. Nigeria, Comm. No. 225/98. 493 ACHPR, OMCT and Others v. Rwanda, Comm. Nos. 27/89, 49/91 & 99/93. 112