PART C: Protection against Torture: Procedures before the African Commission and African Human Rights Court This provision does not empower the African Charter to supervise other treaty systems or international standards. However, the Commission can and has consistently looked to comparative and international practice and jurisprudence in its decision-making.482 Authors of communications and their representatives may also cite or rely on such comparative standards and jurisprudence. As pointed out above, the more nuanced interpretation of Article 5 in the Huri-Laws case derives from reliance on jurisprudence adopted under the European Convention on Human Rights.483 Case law of the Inter-American Court of Human Rights served as interpretative inspiration in another important Commission decision, Zegveld and Ephrem.484 Today, the Commission routinely considers and refers to the jurisprudence of the European Court of Human Rights and the Inter-American Commission, as well as that of the UN Human Rights Committee and the UN Committee Against Torture, in its decisions.485 In giving more exact content to the provision of Article 5, the Commission has referred to the definition of torture under Article 1 of the UN Convention Against Torture (UNCAT).486 The Commission has also invoked the UN Body of Principles for the Protection of All Persons under Any Form of Detention or Imprisonment. In the Ouko case, for example, the Commission relied on Principles 1 and 6 and found a violation of both of these principles.487 Under Articles 3 and 7 of the African Court Protocol, the Court is empowered to consider ‘all cases and disputes concerning the application of the Charter, [the] Protocol and any other relevant human rights instrument ratified by the State 482 For instance in ACHPR, Mouvement Burkinabé des Droits de l’Homme et des Peuples v. Burkina Faso, Comm. No. 204/97, para. 44, the Commission referred to and relied on the UN Declaration on the Protection of All Persons from Enforced Disappearance, adopted 12 February 1993 at the fourty-seventh session of the General Assembly by Resolution A/RES/47/133, 47 UN GAOR Supp. (No. 49) at 207, UN Doc. A/47/49(1992). In SERAC and Another v. Nigeria, Comm. No. 155/96, the Commission made extensive use of the opinions and General Comments of the Committee on Economic, Social and Cultural Rights and the Inter-American Court of Human Rights. See also, Civil Liberties Organisation v. Nigeria, Comm. No. 151/96, in which the Commission places similar reliance on the fair hearing jurisprudence of the European Court of Human Rights. 483 ACHPR, Huri-Laws v. Nigeria, Comm. No. 225/98, para. 41, relying on ECHR, Ireland v. The United Kingdom, App. no. 5310/71, 18 Jan. 1978; see also, European Convention for the Protection of Human Rights and Fundamental Freedoms as amended by Protocols Nos. 11 and 14, adopted 4 November 1950, entered into force 3 September 1953, ETS 5. 484 See ACHPR, Zegveld and Ephrem v. Eritrea, Comm. No. 250/02, relying on Inter-American Court of H.R, Velásquez Rodríguez v. Honduras, Series Case No. 4, Judgment of 29 July 1988. 485 See, e.g., ACHPR, Sudan Human Rights Organisation and COHRE v. Sudan, Comm. Nos. 279/03 & 296/0505, para.123; Egyptian Initiative for Personal Rights and Interights v. Egypt, Comm. No. 334/06; Kenyan Section of the International Commission of Jurists, Law Society of Kenya and Kituo Cha Sheria v. Kenya, Comm. No. 263/02, 36th Ordinary Session (7 December 2004), para. 41. 486 See, e.g., ACHPR, Sudan Human Rights Organisation and COHRE v. Sudan, Comm. Nos. 279/03 & 296/05, para. 160. 487 See ACHPR, John D. Ouko v. Kenya, Comm. No. 232/99. 111