64 Anyangwe/Right to self-determination under the African Charter Republic was the central and salient plank on which the selfdetermination claim was based. The Commission in arriving at its decision erroneously interpreted its own ruling in Katanga to mean that no claim to self-determination under article 20 of the African Charter can succeed in the absence of proof of massive individual human rights violations. Contrary to the averments of the Commission in Gumne, the Katanga case did not posit a universal proposition that the right to self-determination is unavailable in the absence of proof of massive human rights violations. Under the Charter oppression can ground a claim to secessionist selfdetermination. However, such a claim to secession would have to be matched against the principle of territorial integrity. The Commission applied the Katanga ruling to the Southern Cameroons case when the one case is not on all fours with the other. In the context of the African Charter, only two questions need to be answered to determine entitlement to external self-determination under article 20. First, do the people claiming the right to self-determination qualify as a ‘people’ within the meaning of international human rights law? Next, are the said people colonised or oppressed, or alternatively, following the Katanga test, are they the subject of massive individual human rights violations and denied participation in the governance of the country? The Commission grounded its ruling against self-determination for the Southern Cameroons on an obligation on its part to uphold the principle of territorial integrity. But it did not properly apply its mind to that principle. The boundaries of Cameroun Republic became frozen on 1 January 1960 when it achieved independence from France. The Southern Cameroons was then still a British-administered trust territory. The concept of territorial integrity is not univocal. It has an external dimension: territorial integrity threatened from outside the territory; and an internal dimension: territorial integrity threatened from inside the territory itself. Since the Southern Cameroons is not part of Cameroun Republic territory, no question arises of the territorial integrity of Cameroun Republic being threatened from within. Furthermore, arguably, the principle of territorial integrity does not apply to peoples.49 The prohibition of the use or threat of force against territorial integrity applies to external military attacks, and not necessarily against subversion by self-determination. The question of secession is relevant only in respect of the internal aspect of territorial integrity. In Katanga, the boundaries of Zaire were not in dispute. The province of Katanga has always been within the boundaries that Zaire inherited from colonisation on the date of Zairian independence from Belgium in 1960. The inhabitants of Katanga never disputed the fact that Katanga is legally part of Zaire. Their claim was that they simply did not want to be part of Zaire any longer. Among the principles enshrined in the AU Constitutive Act is that of the intangibility of frontiers inherited from colonisation. To uphold territorial integrity in the African context means to uphold boundaries which were inherited from colonisation on the date of independence. The obligation to 49 Kosovo Advisory Opinion.