(2017) 1 African Human Rights Yearbook 47 and repeatedly relied upon by the African Commission’.28 Bulto highlights more of these advantages and states that the utility of cross cutting rights is that they are already established and undisputed rights within different systems and use of the permeability approach has the potential to reveal inherent hidden aspects of socio-economic rights.29 As a result not only will the advantage be in the enhanced normative content of rights but the justiciability of these rights will also be enhanced.30 The elaboration of the content of rights is quite significant as it is through this process that identification of right violations is made easier and state obligations regarding that right can be established. In Legal Resources Foundation v Zambia, the African Commission stressed these sentiments and stated that ‘it is only to the extent that the Commission is prepared to interpret and apply the Charter that Governments would appreciate the extent of its obligations and citizens understand the scope of the rights they have under the Charter.’31 The African Charter in its preamble gives cognisance to the principle of indivisibility, interdependence and interrelatedness of rights provided for in the instrument. It acknowledges that the different categories of rights cannot be disassociated from each other and that the realisation of rights in one category is mutually beneficial to the realisation and enjoyment of other rights. The jurisprudence of the African Commission reflects the recognition of the interdependence of rights. It has used this approach in a number of communications filed before it. The Social and Economic Rights Action Centre and the Centre for Economic and Social Rights v Nigeria (SERAC case), presents the Commission’s classical case in the application of interdependence of rights. The Commission used the interdependence of rights to guarantee protection of the right to housing which is not specifically provided for in the Charter through an inference of its existence from the combined reading of the rights to property, health and family protection.32 Further, the Commission derived the right to food from the right to life, the right to health and the right of all peoples to ‘their economic, social and cultural development with due regard to their freedom and identity and in the equal enjoyment of the common heritage of mankind.’33 In the same communication, the Commission H Quane ‘A further dimension to the interdependence and indivisibility of human rights?: recent developments concerning the rights of indigenous peoples’ (2012) 25 Harvard Human Rights Journal 49; Sisay Alemahu Yeshanew ‘Approaches to the justiciability of economic, social and cultural rights in the jurisprudence of the African Commission on Human and Peoples’ Rights: progress and perspectives’ (2011) 11 African Human Rights Law Journal 334. 28 Bulto (n 3 above). 29 Bulto (n 3 above) 145 30 As above. 31 Legal Resources Foundation v Zambia (2001) AHRLR 84 (ACHPR 2001) para 62. 32 Social and Economic Rights Action Centre (SERAC) & Another v Nigeria (2001) AHRLR 60 (AHRLR 2001) para 63. 33 SERAC (n 32 above) para 64.