160 Murray, Long, Ayeni and Somé/Monitoring implementation of decisions implementation34 and held a panel on implementation as part of its plenary sessions.35 For example, at the 53rd ordinary session of the African Commission in April 2013, the Commission held an implementation hearing in respect of the Endorois case. During the hearing, the parties updated the Commission on the implementation of its decision in the Endorois case.36 Thereafter, the Commission sent a note verbale dated 29 April 2013 to the government of Kenya reminding the government of its pledge during the oral hearing to submit an interim report within 90 days of the hearing and a comprehensive report at the next session (54th ordinary session) of the Commission.37 The oral hearing on implementation was followed by a workshop held on 23 September 2013 on the status of implementation of the Endorois decision, organised by the African Commission’s Working Group on Indigenous Populations/Communities in collaboration with the Endorois Welfare Council.38 Due to the failure of the government of Kenya to participate in the implementation workshop and provide feedback as promised during the oral hearing, the Commission adopted Resolution 257 on 5 November 2013 urging the government of Kenya to comply with its obligations under the African Charter by implementing the Endorois decision. With respect to reporting as a tool for monitoring implementation, the African Commission’s annual report, which includes the annexes of the decisions on communications, has for a number of years included a section outlining ‘the situation of the compliance with its recommendations by the State Parties’.39 This is consolidated by requests from the Executive Council that ‘Parties to Communications to provide the [African Commission] with information regarding implementation of decisions and recommendations of the [African Commission]’.40 The African Court publishes in its activity report a list of States and increasingly detailed information on implementation.41 The information lists the particular reparation ordered by the Court 34 Eg in relation to the Endorois case, African Commission, Resolution 257 Calling on the Republic of Kenya to implement the Endorois decision, adopted November 2013. 35 As a panel at its session in November 2015. See also Meeting between African Commission, African Court, African Committee on Rights and Welfare of the Child and AU, September 2012, Addis Ababa. 36 See African Commission, Thirty-Fourth Annual Activity Report, November 2012 – April 2013 5; Minority Rights Group International ‘The Endorois decision – four years on, the Endorois still await action by the Government of Kenya’ http://minority rights.org/2014/09/23/the-endorois-decision-four-years-on-the-endorois-still-awaitaction-by-the-government-of-kenya/ (accessed 12 July 2017). 37 African Commission (n 23 above). 38 As above. 39 African Commission, Resolution 97 on the importance of the implementation of the recommendations of the African Commission on Human and Peoples’ Rights by States Parties, adopted November 2006 para 3. 40 AU Executive Council, Decision on the Thirty-Sixth Activity Report of the African Commission, 28 April 2014 para 5. 41 See eg Executive Council, Report on the Activities of the African Court on Human and Peoples’ Rights, 22-27 January 2017, para 21; African Court, Mid-Term Activity Report, 1 January – 30 June 2017 section 21(d).

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