The Prohibition of Torture and Ill-treatment in the African Human Rights System: A HANDBOOK FOR VICTIMS AND THEIR ADVOCATES Commission describes incommunicado detention as ‘a gross human rights violation that can lead to other violations such as torture and ill-treatment’.193 In other words, incommunicado detention as such is a violation of Article 6, and it may also lead to a violation of other provisions, such as Article 5, as was found by the Committee in Egyptian Initiative for Personal Rights and INTERIGHTS v. Egypt.194 In this case, the Commission confirmed that incommunicado detention, in and of itself, may constitute cruel, inhuman or degrading treatment or punishment if it is ‘prolonged’ and entails ‘solitary confinement’.195 Given this pronouncement, it is surprising that the Commission did not find a violation of Article 5, as the period of incommunicado detention already totalled more than two years (from September 2001 to November 2003, the date of the Commission’s finding). It is difficult to conceive of a definition of ‘prolonged detention’ that would not apply to the facts in this case, but the Commission’s finding did not explicitly address this point. However, in the case of Article 19 v. Eritrea, the Commission held that 5 years of incommunicado detention constitutes inhuman and degrading treatment.196 In the course of its decision in the Zegfeld and Ephrem case, the Commission also stated that there should be no ‘secret detentions’ and that ‘States must disclose the fact that someone is being detained as well as the place of detention’.197 c. Violations of Human Dignity The African Commission has held that forced nudity, electric shock and sexual assault constitute, together and separately, failure to respect human dignity under Article 5 of the Charter.198 In a number of decisions, the Commission has interpreted ‘dignity’ broadly in reaching its findings. The protection in Article 5 covers not just the physical person of the victim but also the minimal economic and social circumstances required for human existence in any situation.199 For example, in the absence of an express guarantee of a right to housing in the Charter, the Commission has based protection for housing-related rights on the Article 5 guarantee of human dignity, including the prohibition of torture and cruel, inhuman and degrading treatment. In the Modise case,200 the author was rendered stateless when the Respondent State cancelled his Botswana nationality and deported him 193 ACHPR, ACHPR, Zegveld and Ephrem v. Eritrea, Comm. No. 250/2002, 24th Ordinary Session (20 November 2003), para. 55. 194 ACHPR, Egyptian Initiative for Personal Rights and INTERIGHTS v. Egypt, Comm. No. 334/06, para. 219. 195 Ibid. 196 ACHPR, Article 19 v. Eritrea, Comm. No. 275/03, 41st Ordinary Session (30 May 2007). 197 Ibid. 198 ACHPR, Commission Nationale des Droits de l’Homme et des Libertés v. Chad, Comm. No. 74/92; see also, Krishna Achutan (on behalf of Aleke Banda) v. Malawi, Comm. No. 64/92. 199 ACHPR, Sudan Human Rights Organisation & COHRE v. Sudan, Comm. Nos. 279/03 & 296/05. 200 ACHPR, John K. Modise v. Botswana, Comm. No 97/93. 54