A/HRC/18/25 including effective access for the complainant to the investigatory procedure”.26 Furthermore, the Court has repeatedly recognized that the obligation to investigate exists as a result of the general duty of States, under article 1 of the Convention, to “secure” the rights and freedoms contained in the Convention, read in conjunction with the substantive right in question.27 In relation to articles 2 and 3 of the European Convention, the Court has also held that the procedural obligation to carry out an effective investigation under these articles has evolved into a separate autonomous duty.28 14. The African Commission on Human and Peoples’ Rights considers that it is the duty of States to investigate violations as part of their general obligations under article 1 of the African Charter, which requires them to undertake to adopt legislative or other measures to give effect to the rights, duties and freedoms enshrined therein. In fact, in a decision concerning Zimbabwe, the Commission cited with approval the Inter-American Court’s finding in the Velásquez Rodríguez case that the State must, inter alia, “take reasonable steps to prevent human rights violations and use the means at its disposal to carry out a serious investigation of violations committed within its jurisdiction” and held that it represented an authoritative interpretation of an international standard on State duty. The Commission considered that the opinion of the Inter-American Court could also be applied, by extension, to article 1 of the African Charter.29 Furthermore, the Commission found that the established standard of due diligence in the Velásquez Rodriguez case provided a way to measure whether a State has acted with sufficient effort and political will to fulfil its human rights obligations. Under this obligation, States must prevent, investigate and punish acts which impair any of the rights recognized under international human rights law.30 26 27 28 29 30 European Court of Human Rights, Aksoy v. Turkey, app. No. 21987/93, judgment of 18 December 1996, para. 98; see also, for example, Ergi v. Turkey, app. No. 23818/94, judgment of 28 July 1998, paras. 94 and 98. See for example, European Court of Human Rights, Pastor and Ţiclete v. Romania, app. Nos. 30911/06 and 40967/06, judgment of 19 April 2011, paras. 48 and 70; Matayeva and Dadayeva v. Russia, app. No. 49076/06, judgment of 19 April 2011, para. 99; Šilih v. Slovenia, app. No. 71463/01, judgment of 9 April 2009 (Grand Chamber), paras. 153-159, 195-196; Ranstev v. Cyprus and Russia, app. No. 25965/04, judgment of 7 January 2010, paras. 232-233; McCann and Others v. United Kingdom, app. No. 18984/91, judgment of 27 September 1999, para. 61; Ergi v. Turkey, para. 82. See for example, European Court of Human Rights, Efimenko v. Ukraine, app. No. 75726/01, judgment of 25 November 2010, paras. 75, 92; Davydov and Others v. Ukraine, app. Nos. 17674/02 and 39081/02, judgment of 1 July 2010, para. 276; Pastor and Ţiclete v. Romania, para. 48; Varnava and Others v. Turkey, app. Nos. 16064/90, 16065/90, 16066/90, 16068/90, 16069/90, 16070/90, 16071/90, 16072/90 and 16073/90, judgment of 18 September 2009 (Grand Chamber), paras. 191, 194; Salmanoğlu and Polattaş v. Turkey, app. No. 15828/03, judgment of 17 March 2009, para. 99; Šilih v. Slovenia, para. 159; Brecknell v. United Kingdom, app. No. 32457/04, judgment of 27 November 2007, para. 65. African Commission on Human and Peoples’ Rights, Zimbabwe Human Rights NGO Forum v. Zimbabwe, comm. No. 245/02, para. 144. Ibid., para. 146; see also African Commission on Human and Peoples’ Rights, Social and Economic Rights Action Center (SERAC) and Center for Economic and Social Rights (CESR) v. Nigeria, comm. No. 155/96, paras. 44-48, in which the Commission explains the duties incumbent on States pursuant to art. 1 of the African Charter; Amnesty International, Comité Loosli Bachelard, Lawyers’ Committee for Human Rights, Association of Members of the Episcopal Conference of East Africa v. Sudan, comm. No. 48/90-50/91-52/91-89/93, paras. 51-52, 56-57, in which the Commission found that failure to sufficiently investigate constituted violations of arts. 4 and 5 of the African Charter; Mouvement Ivoirien des Droits Humains (MIDH) v. Côte d’Ivoire, comm. No. 246/02, para. 98; also “Principles and guidelines on the right to a fair trial and legal assistance in Africa” (1999), sect. C, Right to an effective remedy; “Resolution on guidelines and measures for the prohibition and 7