The Prohibition of Torture and Ill-treatment in the African Human Rights System: A HANDBOOK FOR VICTIMS AND THEIR ADVOCATES recommendations, which undoubtedly contributes to the enforcement problem faced by the Commission. Another factor contributing to the lack of enforcement of Commission decisions is the fact that they are termed ‘recommendations’, which may be perceived as non-binding on States. With the establishment of the Court, it is anticipated that enforcement of the Commission’s decisions will be strengthened through the referral of cases by the Commission to the Court, which issues binding decisions. It is as yet too early in the Court’s functional existence to comment on its impact on enforcement of decisions in referral cases. Furthermore, recommendations of the Commission are often vague and imprecise. For example, recommendations for ‘legislative amendments’ do not include specific detail as to what such changes should consist of, which poses problems not only in terms of implementation but also for the effective monitoring of such implementation. Commentators have also pointed to the challenges faced by States with regard to implementation, in terms of a lack of financial resources to compensate victims as well as and inadequate or insufficient coordination amongst State parties, under whose remit the implementation of Commission decisions falls.520 Though the sub-regional bodies also face challenges regarding enforcement of decisions, the binding nature of these decisions goes some way in effectuating implementation. The 2005 Protocol to the Treaty establishing the ECOWAS Court of Justice includes a requirement that execution of the Court’s judgments must take the form of a Writ of Execution, which the Chief Registrar must submit to the relevant State.521 States are required to establish or identify the national authority responsible for implementing judgments of the Court. Decisions of the EAC Court of Justice are binding and can be subject to appeal. Though the EAC Treaty establishing the Court includes provisions for ensuring implementation of decisions, there are no procedures to initiate consequences for States that fail to do so.522 X. Inter-State Communications As of the time of writing, the Commission has finalised one inter-State communication. The case Democratic Republic of the Congo v. Burundi, Rwanda and Uganda523 arose from an undeclared ‘war’ involving four States in the ‘Great Lakes’ area. The DRC directed allegations of serious human rights violations against the armed forces of the countries named above, committed mainly within the territory of the 520 521 522 523 118 Ibid. Protocol on the Ecowas Cort of Justice, Article 24. EAC Treaty, Articles 30-33. ACHPR, DRC v. Burundi, Rwanda and Uganda, Comm. No. 227/99.