(2017) 1 African Human Rights Yearbook 161 and then provides detail on what the State has done, if anything, to implement that measure. In one situation, with respect to Libya, it adopted an Interim Report noting that ‘Libya has failed to comply with a judgment of the Court’.’42 It submitted this report to the AU Assembly in accordance with article 31 of the Protocol and Rule 51(4) of the Rules of Court, urging the Assembly to express itself on Libya’s non-compliance with the Court Order and to call upon Libya to comply forthwith and, also for Libya to report to the Court within 14 days on what measures Libya has taken to comply with the Court Order; the Assembly to adopt a decision calling upon all Member States of the African Union to comply with and implement Judgments and Orders of the Court, in accordance with Article 30 of the Protocol; the Assembly to take such other measures as it deems appropriate to ensure that Libya fully complies with the Court Order.43 The African Commission can offer its good offices to parties to a communication and facilitate dialogue between them in the implementation of its decisions.44 Whether the parties make use of this potential as often as they might is a question to be considered in further research.45 In carrying out its role under the Protocol and the Rules of Court, the African Court has required, as part of the judgment or ruling in reparations, for States to report back to it within a period of time on the measures they have taken to implement the judgment.46 The African Court, we were informed,47 also writes to States to request information and regularly updates this information. Neither the African Commission nor African Court appears to have an electronic case management database that incorporates data on the implementation of the decisions and rulings. Both the African Court and the African Commission have then used any information they have collated to make an assessment on the extent to which the State has implemented the judgment or decision. For the African Commission this is not done consistently. For example, there are only a handful of cases where the African Commission has made more detailed analysis and statements on a State’s failure to implement, prompted, it would appear, by sustained campaigns from the litigants or interested civil society organisations.48 42 African Court, Interim Report of the African Court notifying the Executive Council of non-compliance by a State (Interim Report on Libya), 17 May 2013 para 8. 43 African Court (n 42 above) paras 9-10; AU Executive Council (n 41 above) para 56. 44 African Commission, Final communiqué of the Workshop on the Status of Implementation of the Endorois Decision of the African Commission, 23 September 2013 para 4. 45 NJ Udombana ‘Towards the African Court on Human and Peoples’ Rights: better later than never’ (2000) 3 Yale Human Rights and Development Law Journal 45; ST Ebobrah, ‘Towards a positive application of complementarity in the African human rights system: issues of functions and relations’ (2011) 22 European Journal of International Law 663-688. 46 Ruling on Reparations in Mtikila v Tanzania, Application 11/2011, 47 Interview D5, May 2017; Interview D8, May 2017. 48 African Commission (n 34 above).