56 Chekera-Radu/Women’s land and property rights ‘[g]uarantees of equality and non-discrimination should be interpreted, to the greatest extent possible.’67 In formulating effective equality in the enjoyment of socio economic rights, the Commission has included the hallmarks of substantive equality by obliging states to pay attention to vulnerable groups and the factors that impede their enjoyment of rights on an equal basis. Further, the Commission clearly states that the right to equality encompasses the adoption of special measures ‘in order to reduce or suppress conditions that perpetuate discrimination and to realise substantive equality.’68 States are also required to take into account all patterns of inequality such as those based on sex, religion and ethnicity in measures aimed at ensuring equality. The African Commission’s concluding observations and recommendations to different states allow a glimpse of the body’s interpretation of equality. The utility of concluding observations lie in the recommendations that the Commission gives to states on how to implement the provisions of the Charter or the obligations of states in relation to the rights in the African Union’s treaties. The concluding observations to many African states have consistently included key components of a substantive equality approach. For instance, the Commission’s observations and recommendations have highlighted that even in the presence of measures protecting the rights of women there are structural factors such as partriarchal cultures resulting in inequality which require attention in order to ensure women’s actual enjoyment of the right to equality.69 Not only do these observations and recommendations recognise the need to consider the several factors that hamper the enjoyment of equality between different groups, the Commission has consistently, in keeping with substantive equality, commended or called upon states to implement measures that level the playing field between men and women and are aimed at ensuring equality. The Commission has on several occasions commended states on the implementation of provisional measures such as affirmative action in various spheres or called upon states to implement such measures.70 The concluding observations of the Commission have also addressed themselves to 67 68 34. 69 Principles and Guidelines on the Implementation of ESCR (n 18 above) para 31. Principles and Guidelines on the Implementation of ESCR (n 18 above) paras 31 & Concluding Observations and Recommendations on the Initial Periodic Report of the Republic of Liberia on the Implementation of the African Charter on Human and Peoples’ Rights. 55th Ordinary Session, held from 28 April to 12 May 2014, in Luanda, Angola, and adopted at its 17th Extra-Ordinary Session, held from 19 to 28 February 2015, in Banjul, The Gambia. 70 Concluding Observations and Recommendations on the Initial and Combined Periodic Report of the Republic of Malawi on the Implementation of the African Charter on Human and Peoples’ Rights (1995 – 2013) considered during its 56th Ordinary Session, held from 21 April – 7 May 2015 in Banjul, The Gambia and adopted 57th Ordinary Session held from 04 to 18 November, 2015, in Banjul, Republic of The Gambia; Concluding Observations and Recommendations on the Consolidated 2nd to 10th Periodic Report of the United Republic of Tanzania adopted at the 43rd Ordinary Session of the African Commission on Human and Peoples’ Rights held from 7 to 22 May 2008, Ezulwini, Kingdom of Swaziland