(2017) 1 African Human Rights Yearbook 155 necessarily mean that the body will not also take some steps to, for instance, assess implementation as well. A related issue is that whatever role these bodies play must not impact on their neutrality and independence. This applies equally to the African Commission as to the African Court. The legitimacy and credibility of the bodies come in part from the perception of them as independent and their ability to be resolute in the face of pressures from States or other actors.14 Some of the tasks employed in monitoring implementation potentially could compromise this neutrality. So, for example, on the one hand one might see the benefits for a Commissioner who lived in the State against which a decision was adopted to be a source of expertise for the State authorities when determining how to implement that decision. On the other hand, his or her lack of engagement with the case prior to its adoption, in accordance with the Rules of Procedure to ensure neutrality,15 does not make this a straightforward proposition. Bearing in mind the importance of independence, the question then becomes: What roles do the treaty provisions and rules presume? 3 TREATY PROVISIONS AND RULES OF PROCEDURE/RULES OF COURT Article 1 of the African Charter requires States Parties to ‘recognise the rights, duties and freedoms enshrined in the Charter’ and to ‘undertake to adopt legislative or other measures to give effect to them’. The African Commission has a broad mandate in article 45 to promote, protect and interpret the African Charter. Article 46 further enables it to ‘resort to any appropriate method of investigation’; it may hear from the Chairperson of the AU Commission or any other person capable of enlightening it.16 Rule 98(4) of the African Commission’s Rules of Procedure requires the State to report to the African Commission on measures taken to implement provisional measures. Rule 112 has further detail on ‘follow-up’ on the recommendations of the Commission. This Rule provides as follows: 14 1. After the consideration of the Commission’s Activity Report by the Assembly, the Secretary shall notify the parties within thirty (30) days that they may disseminate the decision. 2. In the event of a decision against a State Party, the parties shall inform the Commission in writing, within one hundred and eighty (180) days of being informed of the decision in accordance with paragraph one, of all measures, if any, taken or being taken by the State Party to implement the decision of the Commission. Open Society Justice Initiative (n 3 above) 11; H Koh ‘Review essay: why do nations obey international law?’ (1997) 106 Yale Law Journal 2599 2602. 15 Rule 101 of the African Commission’s Rules of Procedure. 16 Article 46 of the African Charter.