Cultural Rights (for economic, social and cultural rights) and the International Covenant on Civil and Political Rights (for civil and political rights), thus creating 2 sets of rights. This did not influence the Organisation of African Unity at the time, which combined both civil and political rights and ESCR in the same document, which did not consequently have resource consideration for the implementation of rights. In 2001, the African Commission made it clear in the SERAC versus Nigeria case that there is an interdependence of rights, the obligation to protect, respect and fulfil rights irrespective of the type of rights. This was reiterated in the case of Purohit versus the Gambia. These are the ways in which NHRIs has followed up on the implementation of the decisions of the African Commission Kenya Endorses case: This was the ffirst case of the African Commission to recognise the rights of indigenous people in Kenya – The Endorois filed this case as a consequence of their eviction from their land in Kenya and were challenging the violations of several rights in the African charter. Unfortunately, not much has happened but the NHRI has participated by convening other stakeholders and working on an advisory to the State on what if implemented would lead to a realisation of the rights in the African Charter. The government formed a task force and unfortunately it was not properly funded and they never had the opportunity to present the final report. Ogiek case: The Ogiek case task force received inputs from different stakeholders and filed its final reports to the authorities about a year ago. Unfortunately, the report is not yet public. Nigeria SERAC versus Nigeria is a landmark decision that has great effect on the jurisprudence on environmental protection. The NHRI has taken several steps to implement the decisions such as using the decision of the African Commission to resolve/deal with complaints, creating awareness at the local level on the implementation of ESCR citing decisions of the African Charter. In 2016 the NHRI created a human rights and investigation panel in Nigeria on oil pollution and oil degradation following the decisions of the African Commission. However, in the court of appeal, the decision of the court of first instance were reversed in that oil issues are not rights issues. They have appealed this decision to the Supreme Court and one of the authorities in this case is that of SERAC versus Nigeria. The NHRI has also created a link to the decisions of the African Commission so that these decisions can be made accessible locally. It has further adopted a national action 16

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