PART C: Protection against Torture: Procedures before the African Commission and African Human Rights Court 3. Locus Standi Before the issue of admissibility is considered, it must be determined whether a complainant has standing (locus standi) to bring a complaint. Under the African Charter, standing is not explicitly dealt with; however, the Commission has adopted a very broad approach, extending access to both victims and NGOs. Unlike the UN Human Rights Committee, the CAT Committee or the European Convention system, any person may initiate a communication in the African system. The authors need not be victims, their families or persons authorised by them.309 In Baes v. Zaire,310 for example, a Danish national submitted a communication regarding the illegal detention of one of her colleagues at the University of Kinshasa, where she was working at the time. Moreover, authors do not need to be citizens or residents of a State party to the Charter, nor a resident of, or located in, any AU Member State.311 In Haregewoin Gebre-Sellaise & IHRDA (on behalf of former Dergue officials) v. Ethiopia, the respondent State challenged the admissibility of the complaint on grounds that the IHRDA (Institute for Human Rights and Development in Africa) was not registered in Ethiopia, however the Commission affirmed that there is no requirement of citizenship to bring a complaint before it.312 Any ‘person’, whether individual or corporate, may submit a communication. NGOs need not enjoy observer status with the Commission to be granted standing to submit a communication. Locus standi before the African Court on Human and Peoples’ rights is distinctly different regarding contentious cases (those involving disputes about alleged violations) and advisory opinions. Under the African Human Rights Court Protocol, the following entities may institute contentious cases before the Court:313 a) b) c) d) e) the African Commission; a State party in a case in which it was a Complainant before the Commission; a State party in a case in which it was a Respondent before the Commission; a State party whose citizen has been a victim of human rights violations; and African inter-governmental organizations. 309 ACHPR, Organisation Mondiale contre la Torture (OMCT) v. Zaire, Comm. No. 25/89, para. 92; ACHPR, Haregewoin Gebre-Sellassie & IHRDA (on behalf of former Dergue Officials) v. Ethiopia, Comm. No. 301/05, para 105. . 310 ACHPR, Maria Baes v. Democratic Republic of the Congo (former Zaire), Comm. No. 31/89, 17th Ordinary Session (22 March 1995). 311 ACHPR, Spilg and Mack & DITSHWANELO (on behalf of Lehlohonolo Bernard Kobedi) v. Botswana, Comm. No. 277/03, 10th Extraordinary Session (12 October 2013). 312 ACHPR, Haregewoin Gebre-Sellassie & IHRDA (on behalf of former Dergue Officials) v. Ethiopia, Comm. No. 301/05, para. 64. 313 African Human Rights Court Protocol, supra note 22, Article 5(1). 79