PART C: Protection against Torture: Procedures before the African Commission and African Human Rights Court while the request of Mali was withdrawn.321 Two advisory opinion requests were pending as of November 2013, including a request from South African civil society organisations regarding the legality of the suspension of the SADC Tribunal.322 Locus standi before the sub-regional bodies The ECOWAS Court of Justice has also interpreted locus standi requirements broadly. In the case of SERAP v. Nigeria, the State made several objections on a number of grounds, including that the complainant lacked the requisite locus standi to initiate proceedings. Since the complainant, an NGO, had failed to show that it had suffered any damage, loss or personal injury resulting from acts alleged in the complaint, the State contended that ‘the plaintiff has no right, interest or obligation that can give them the right to maintain this action; or alternatively that the plaintiff does not have a sufficient or special interest in the performance of the duty sought to be enforced by the institution of this action’.323 The Court undertook a review of the interpretation of locus standi in public interest cases, and concluded that in such litigation, ‘the plaintiff need not show that he has suffered any personal injury or has a special interest that needs to be protected to have standing. Plaintiff must establish that there is a public right which is worthy of protection which has been allegedly breached and that the matter in question is justiciable’.324 The EAC Court of Justice has taken a similar position.325 4. Admissibility A complaint to the African Commission may be initiated by a communication addressed to the Secretariat of the African Commission, located in Banjul, The Gambia. A communication is a written document alleging breaches of the African Charter by a State Party. To be considered by the Commission, a communication must fulfil the admissibility requirements contained in Article 56 of the Charter. These requirements are cumulative, meaning that they must all be satisfied for the communication to be declared admissible by the Commission. The Court’s admissibility requirements are the same as those of the Commission under Article 56 of the African Charter.326 The Court may also request the opinion 321 African Court, Request No 001/2011 by the Republic of Mali (16 May 2012). 322 African Court, Request No 002/2012 by The Pan African Lawyers’ Union (PALU) and Southern African Litigation Centre (6 August 2013). On the suspension of the SADC Tribunal, see Part A , Section VI(3). 323 ECOWAS Court of Justice, SERAP v. Nigeria, ECW/CCJ/APP/08 (27 October 2009), para. 20. 324 Ibid., para 33. 325 EACJ, East African Law Society, Law Society of Kenya, Tanganyika Law Society, Uganda Law Society, Zanzibar Law Society v. Attorney General of Kenya, Attorney General of Tanzania, Attorney General of Uganda, Secretary General of the East African Community, App. No. 9 of 2007 (11 July 2007). 326 African Charter, supra note 9, art. 56(1)-(7); African Human Rights Court Protocol, supra note 22, Article 6. 81