162 Murray, Long, Ayeni and Somé/Monitoring implementation of decisions The African Court has not published any criteria on what amounts to ‘full’ or ‘partial’ implementation, although it has used these terms. For example: While welcoming the efforts made by Burkina Faso and Tanzania to implement the Court’s judgments, the Court notes that the two countries are yet to fully comply with the orders of the Court in those judgments, and further notes Tanzania’s unwillingness to comply with the Court’s Orders for Provisional Measures.49 This terminology could, however, be read as relating to the number of specific orders in the judgment, rather than an assessment of the nature of the measures taken with respect to each particular order. There is no information that is consistently publicly available on how the African Commission or African Court assess the accuracy or test the veracity of information given to them on the extent to which the State has implemented the decision or judgment. In the end it may come down to whether the complainant or applicant accepts and is content with what the State claims it has done. 5 CONCLUSIONS Our research asserts the following conclusions. It reveals that although the bodies monitoring implementation, in our context, the African Commission or the African Court, are expected to play various roles, there appears to be no coherent or strategic approach. The consequences of this insight are far-reaching. First, there are times at which none of these tasks are being carried out because the bodies do not consider it their responsibility to do so. Second, many of these tasks are being carried out but not well or consistently well. Third, there is no coherent picture from those within or outside the bodies as to whether these roles are appropriate or not, whether they themselves are best placed to play them, play them on some occasions and not others, or whether others should be doing these tasks instead. Finally, one of the reasons why the African Court and African Commission appear to be carrying out the variety of monitoring activities is because they are doing so instead of putting a more holistic and coherent system in place, particularly at the AU level. The sub-committee envisaged by Rule 112(8) of the African Commission’s Rules of Procedure has not become operational and any real monitoring or enforcement from the AU level, beyond simply calling on states to implement decisions of the two bodies,50 is therefore limited and in many respects absent. 49 AU Executive Council, Report on the Activities of the African Court to the Executive Council, 22-27 January 2017 para 57. 50 Eg AU Executive Council (n 40 above) para 4, where it ‘call[ed] on states to implement the decisions and recommendations’ of the African Commission as well as to ‘respond to the ACHPR’s Urgent Appeals and comply with Orders for Provisional Measures issued by the ACHPR’; AU Executive Council, Decision on the Thirty-Fifth Activity Report of The African Commission, 21-28 January 2014 para 4: ‘Calls upon Member States to implement decisions and recommendations of the ACHPR, respond to Urgent Appeals from the ACHPR, and to comply with Provisional Measures issued by the ACHPR’; AU Executive Council, Decision on the Thirty-Fourth Activity Report of the African Commission, 19-23 May 2013 para 4: ‘Exhorts State Parties to take concerted action to address the human rights issues that the ACHPR has identified as being