concluded the existence of the crime of sexual molestation, which includes exposing private parts, sexual harassment and touching the genitals. 185. They argue that the element of criminal intention was not established in this offence as the injuries sustained by the Victims were as a result of battery and clashes, adding that the PPO investigations concluded that the perpetrators were unknown. Before the African Commission determines whether the acts inflicted on AC HP R 186. the Victims amounted to inhuman and degrading treatment, and whether there was pain and suffering, it will first of all attempt to define the term „inhuman and degrading treatment.‟ 187. The African Commission‟s jurisprudence has established the scope of inhuman and degrading treatment, which does not only include physical and psychological suffering. In International Pen and Others v. Nigeria, for instance, the African Commission held that: Article 5 of the African Charter prohibits not only torture, but also cruel, inhuman or degrading treatment. This includes not only actions which cause serious physical or psychological suffering, but which humiliate the individual or force him or her to act against his will or conscience.56 188. The African Commission has also noted that violations under Article 5 of the African Charter should also be established based on the circumstances of each case. In Curtis Doebbler v Sudan, the African Commission ruled that: 56 Communications 137/94, 139/94, 154/96 & 161/97- International Pen, Constitutional Rights Project, Interights on behalf of Ken Saro-Wiwa Jr. and Civil Liberties Organisation v. Nigeria(ACHPR). para. 79 53