made known to victims and effective access to justice for victims should be ensured.366 This is especially important with regard to vulnerable groups of victims.367 The ACHPR has highlighted that in the case of a change in government, the new government will inherit all reparation obligations of the previous government.368 Forms of reparations International law recognises five forms of reparations; including compensation, restitution, guarantees of non-repetition, rehabilitation, and satisfaction. The right to truth is entwined with each of these forms of reparations.375 See sub-section above for more on this.376 Adequate. Reparations should be appropriate and proportionate to the gravity of the violation and the circumstances of each case.369 They should also be adequate, effective, comprehensive, speedy and timely.370 The ACHPR considers that failure to provide prompt access to redress is a de facto denial of redress.371 Compensation. Where damage can be assessed economically, compensation should be provided.377 Compensation has to be adequate; that is, proportionate to the gravity of the violation and to the suffering of the victim and the family.378 Monetary compensation should be granted for physical or mental harm, lost opportunities, material damages and loss of earnings, harm to reputation and costs required for legal and expert assistance.379 The ACHPR has specified that human lives have no price and as such, reparations must be substantial in order to be adequate.380 This is illustrated by the case of Jestina Mukoko, who was awarded $150,000 USD by the High Court of Zimbabwe in compensation for the abduction, detention Victim-Oriented and Non-Discriminatory. States “should address linguistic and literacy barriers” in the context of reparations.372 Reparation programmes should recognise the particular harm suffered by women in the context of ED.373 The ACHPR aspires to adopt a holistic approach to reparations; and takes a victim-centered approach to redress.374 366 OHCHR, Basic Principles and Guidelines on the Right to a Remedy and Reparation for Victims of Gross Violations of International Human Rights Law and Serious Violations of International Humanitarian Law, UN Doc. A/RES/60/147, Annex, 21 March 2006, para. 12(a), see also para. 24. 367 UNGA, Special Rapporteur on Torture, Report, UN Doc. A/HRC/7/3, 15 January 2008, paras. 61-62. States should also “take measures to minimize the inconvenience to victims and their representatives, protect against unlawful interference with their privacy as appropriate and ensure their safety from intimidation and retaliation, as well as that of their families and witnesses, before, during and after judicial, administrative, or other proceedings that affect the interests of victims” (OHCHR, Basic Principles and Guidelines on the Right to a Remedy and Reparation for Victims of Gross Violations of International Human Rights Law and Serious Violations of International Humanitarian Law, UN Doc. A/RES/60/147, Annex, 21 March 2006, para. 12(b)). 368 ACHPR, Achutan v. Malawi, Communications Nos. 64/92, 78/92, 3 November 1994, para. 12. 369 OHCHR, Basic Principles and Guidelines on the Right to a Remedy and Reparation for Victims of Gross Violations of International Human Rights Law and Serious Violations of International Humanitarian Law, UN Doc. A/RES/60/147, Annex, 21 March 2006, paras. 15, 18. 370 ACHPR, General Comment No. 4 on the African Charter on Human and Peoples’ Rights, supra note 164, 2017; IACtHR, Mónago Carhuaricra v. Peru, Case No. 10.826, Report No. 45/00, OEA/Ser.L/V/II.106, doc 3, rev. 1999, Recommendation No. 3; ECtHR, Paulino Tomás v. Portugal, Reports of Judgment and Decisions, 2003; Çelik and Imret v. Turkey, Application No. 41993/98, 27 July 2004, para. 59; see also: HRCt, General Comment no. 32, UN Doc. CCPR/C/GC/32, 23 August 2007. 371 ACHPR, General Comment No. 4 on the African Charter on Human and Peoples’ Rights, supra note 164, 2017, para. 26; Similarly, the IACtHR held that the right to a remedy “refer[s] not only to the mere existence of […] remedies, but also to their adequacy and effectiveness” (IACtHR, Velásquez Rodríguez v. Honduras, 29 July 1988, para. 63; see also IACtHR, Monago Carhuaricra v. Peru, Report No. 45/00, 13 April 2000, para. 50.). 372 WGEID, General Comment on Women Affected by Enforced Disappearances, UN Doc. A/HRC/WGEID/98/2, 14 February 2013, para. 43. 373 Ibid, para. 39. 374 ACHPR, General Comment No. 4 on the African Charter on Human and Peoples’ Rights, supra note 164, 2017, para. 18. 375 IACtHR, Trujillo Oroza v. Bolivia, 27 February 2002, Reparations, paras. 114-115; Bámaca Velásquez v. Guatemala, 22 February 2002, Reparations, para. 76. 376 OHCHR, Basic Principles and Guidelines, supra note 219, para. 24. 377 OHCHR, Basic Principles and Guidelines, supra note 219, para. 20. 378 WGEID, General Comment on Article 19, supra note 357, para.73; see also: OHCHR, Basic Principles and Guidelines, supra note 219, para. 15. Where monetary compensation is awarded to child victims, States “should take into account the age and maturity of the child and develop an appropriate arrangement for collection,” such as the use of a guardian; WGEID, General Comment on Children and Enforced Disappearances, UN Doc. A/HRC/WGEDI/98/1, 14 February 2013, para. 32. 379 WGEID, General Comment on Article 19, supra note 357, para. 73; see also: OHCHR, Basic Principles and Guidelines note supra 219, para. 20. The IACtHR has established that the pecuniary damages are meant to cover the “loss of, or detriment to, the victims’ income, expenses made as a result of facts and consequences of a pecuniary nature with a causal connection to the facts of the case”; IACtHR, Bámaca Velásquez v. Guatemala, Reparations and Costs, 22 February 2002, para. 43; Gomes Lund and others (Guerrilha do Araguaia) v. Brazil, Preliminary Objections, Merits, Reparations and Costs, 24 November 2010, para. 298; and Cabrera García and Montiel Flores v. México, Preliminary Objection, Merits, Reparations and Costs, 26 November 2010, para. 248. However, damage to one’s “life-plan”, while it should be recognised and compensation provided, is not easily quantifiable; IACtHR, Loayza Tamayo v. Peru, Order, 3 February 2001, para. 60. 380 ACHPR, Institute of Human Rights and Development in Africa and others v. DRC, Communication 393/10, June 2016, para. 150. In this case, an amount of USD 300,000 was rewarded to each victim for their loss, in addition to other pecuniary damages for the looting of their goods. 54