PART B: Substantive Norms on Torture in the African Regional Human Rights System to South Africa for political reasons. South Africa in turn deported him to what was then Bophuthatswana, which in turn deported him back to Botswana. Unable to determine where to keep the victim, the authorities of the Respondent State left him homeless for an extended period in a specially created strip of territory along the South African border called ‘no-man’s land’. The Commission found that by denying Mr Modise his nationality and deporting him repeatedly, Botswana violated his right to respect for human dignity. The Commission also found that such enforced homelessness was inhuman and degrading treatment that offended ‘the dignity of human beings and thus violated Article 5’.201 This case supports the conclusion that involuntary or forced displacement directly attributable to the State or its agencies is a violation of the right to respect for human dignity. The case further supports the argument that victims of such displacement are entitled in such cases to minimum guarantees of assistance, including shelter. In another case, Purohit and Moore v. The Gambia, the Commission clarified that personal suffering and indignity ‘can take many forms, and will depend on the particular circumstances of each case brought before the African Commission’.202 The particular circumstances may require that violations of the right to respect for human dignity are found in conjunction with other provisions of the Charter, such as the right to health. The Mauritania cases,203 for example, comprised five consolidated communications arising from developments in Mauritania between 1986 and 1992. Briefly, these communications alleged the existence in that State of slavery and analogous practices, and of institutionalized racial discrimination perpetrated by the ruling Beydane (Moor) community against the more populous black community. The cases alleged that black Mauritanians were enslaved, routinely evicted or displaced from their lands, which were then confiscated by the Government. The communication also alleged that some detainees had, among other things, been starved to death, left to die in severe weather without blankets or clothing and were deprived of medical attention. The Commission found that starving prisoners and depriving them of blankets, clothing and health care violated both the guarantee of respect for human dignity in Article 5 and the right to health in Article 16 of the Charter.204 Similarly, in the case of Sudan Human Rights Organisation and COHRE v. Sudan, the Commission agreed with the UN Committee Against Torture205 that ‘forced 201 Ibid., para. 32. 202 ACHPR, Purohit and Moore v. The Gambia, Comm. No. 241/2001, 33rd Ordinary Session (May 2003), para. 77. 203 ACHPR, Malawi African Association and Others v. Mauritania, Comm. Nos. 54/91, 61/91, 98/93, 164-169/97 & 210/98. 204 Ibid., para. 122. 55