The Prohibition of Torture and Ill-treatment in the African Human Rights System: A HANDBOOK FOR VICTIMS AND THEIR ADVOCATES of the Commission when considering the admissibility of a case.327 In practice, although it is empowered to do so, the Court has so far not reopened the admissibility of cases which the African Commission has previously decided on the merits. However, the Court will be able to exercise original admissibility jurisdiction under Article 6(2) of the African Court Protocol in those exceptional cases which may be initiated by NGOs under Article 5(3) of the Protocol; however, as mentioned earlier, such cases may only be brought against States that have recognised the Court’s jurisdiction under Article 34(6) of the Protocol. The admissibility requirements under Article 56 are now examined in turn. a. Communications Must Disclose Authors and Their Contact Information328 Communications should indicate the name and addresses of the complainants (or ‘authors’) though authors can request anonymity.329 While it is not required that the alleged victims’ names and addresses be included, the Commission has suggested that these be included,330 although victims can also request anonymity.331 There is no requirement under the Charter or the relevant case law that cases be brought only by neutral persons or organisations.332 b. Violations Alleged Must Have Occurred After Ratification of the Charter The Commission may only consider allegations of violations that occurred after the respondent State ratified or acceded to the Charter. Where the violations alleged began before the ratification, the complaint may nevertheless be admissible if the violations substantially continued after ratification.333 For instance, in the Modise case,334 the alleged violation began in about 1977, long before the adoption of the African Charter. The author, a Botswana national who was stripped of his 327 African Human Rights Court Protocol, ibid. 328 African Charter, supra note 9, art. 56(1). 329 ACHPR, Darfur Relief and Documentation Centre v. Sudan, Communication 310/05, 46th Ordinary Session (25 November 2009), para. 65. 330 ACHPR, Malawi Africa Association and Others v. Mauritania, Comm. Nos. 54/91, 61/91, 98/93, 164-169/97, 210/98; Kevin Mgwanga Gunme et. al. v. Cameroon, Comm. No. 266/03. See also: formation Sheet No.2, Guidelines for the Submission of Communications, supra note 301. 331 ACHPR, Malawi Africa Association and Others v. Mauritania, Comm. Nos. 54/91, 61/91, 98/93, 164-169/97, 210/98; Kevin Mgwanga Gunme et. al. v. Cameroon, Comm. No. 266/03. See also: formation Sheet No.2, Guidelines for the Submission of Communications, supra note 301. 332 ACHPR, INTERIGHTS (on behalf of the Pan African Movement and Citizens for Peace in Eritrea) v. Ethiopia Comm. Nos. 233/99 & 234/99, 33rd Ordinary Session (29 May 2003), ), para. 47. 333 See, ACHPR, Emgba Louis Mekongo v. Cameroon, Comm. No. 59/91, 17th Ordinary Session (22 March 1995); John K. Modise v. Botswana, Comm. No. 97/93 334 ACHPR, John K. Modise v. Botswana, Comm. No. 97/93. 82