PART C: Protection against Torture: Procedures before the African Commission and African Human Rights Court formulation urging the Government to ‘adopt measures in conformity with’ the Commission’s decision. More detailed remedies requiring specific State action have been ordered in a number of cases. These have been varied, including recommendations for legislative changes, adequate compensation for victims, and improvement of conditions of detention. The following recommendations have been made in specific cases: (1) (2) (3) (4) (5) (6) (7) (8) That the Government ‘put an end to’ violations of Article 5 and other violations;494 To ‘improve’ the ‘conditions of detention’ of civilians held in military detention centres;495 To ensure persons in detention are provided with medical treatment and care;496 To ensure regular supervision or monitoring in places of detention by qualified and/or experienced persons;497 To take ‘appropriate measures’ to ensure payment of ‘adequate compensation in line with international standards’ to victims of violations498 and ensure victims are given ‘effective remedies, including restitution and compensation;499 To release persons who have been detained without charge or trial, or who have been convicted in a trial in violation of Article 7;500 To conduct effective official investigations into abuses and prosecute those responsible;501 Legislative changes.502 The Commission’s jurisprudence has been varied in its practice relating to awards of reparation in Article 5 cases, in some cases calling for payment of compensation to victims and in others making more general recommendations. For example, in the case of Kevin Mgwanga Gunme et. al. v. Cameroon, the Commission found the State 494 495 496 497 498 499 500 501 502 ACHPR, Amnesty International and Others v. Sudan, Comm. Nos. 48/90, 50/91, 52/91 & 89/93, para. 85. ACHPR, Civil Liberties Organisation v. Nigeria, Comm. No. 151/96, para. 29. ACHPR, IHRDA v. Angola, Comm. No. 292/04, para. 87. Ibid. para. 87. ACHPR, Malawi Africa Association and Others v. Mauritania, Comm. Nos. 54/91, 61/91, 98/93, 164-169/97, 210/98; Article 19 v. Eritrea, Comm. No. 275/03; Egyptian Initiative for Personal Rights v. Egypt Comm. No. 334/06. ACHPR, Sudan Human Rights Organisation and COHRE v. Sudan, Comm. Nos. 279/03 & 296/05, para. 241. ACHPR, Egyptian Initiative for Personal Rights v. Egypt, Comm. No. 334/06. ACHPR, Sudan Human Rights Organisation and COHRE v. Sudan, Comm. Nos. 279/03 & 296/05, para. 241; Gabriel Shumba v. Zimbabwe, Comm. No. 288/04. See ACHPR, Avocats Sans Frontieres v. Burundi, Comm. No. 231/99, 28th Ordinary Session (6 November 2000), para. 34; Egyptian Initiative for Personal Rights v. Egypt, Comm. No. 334/06, para. 233. 113

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