156 Murray, Long, Ayeni and Somé/Monitoring implementation of decisions 3. Within ninety (90) days of receipt of the State’s written response, the Commission may invite the State concerned to submit further information on the measures it has taken in response to its decision. If no response is received from the State, the Commission may send a reminder to the State Party concerned to submit its information within ninety (90) days from the date of the reminder. 4. The Rapporteur for the Communication, or any other member of the Commission designated for this purpose, shall monitor the measures taken by the State Party to give effect to the Commission’s recommendations on each Communication. 5. The Rapporteur may make such contacts and take such action as may be appropriate to fulfill his/her assignment including recommendations for further action by the Commission as may be necessary. 6. At each Ordinary Session, the Rapporteur shall present the report during the Public Session on the implementation of the Commission’s recommendations. 7. The Commission shall draw the attention of the Sub-Committee of the Permanent Representatives Committee and the Executive Council on the Implementation of the Decisions of the African Union, to any situations of non-compliance with the Commission’s decisions. 8. The Commission shall include information on any follow-up activities in its Activity Report. In setting out when the African Commission is able to submit a case to the African Court, Rules 118(1) and (2) provide that this can be done where the African Commission ‘considers that the State has not complied or is unwilling to comply with its recommendations in respect of the communication within the period stated in Rule 112(2)’ and where it ‘considers that the State has not complied with the Provisional Measures requested’. Rule 125 enables the African Commission to request the AU Assembly, when it submits its activity report, ‘to take necessary measures to implement its decisions’ and for the African Commission to ‘bring all its recommendations to the attention of the Sub-Committee on the Implementation of the Decisions of the African Union of the Permanent Representatives Committee’. Article 29(2) of the African Court Protocol states that the Executive Council of the AU ‘shall also be notified of the judgment and shall monitor its execution on behalf of the Assembly’. Under article 30 of the Protocol, States parties are required to ‘comply with the judgment in any case to which they are parties within the time stipulated by the Court and to guarantee its execution’ and in compliance with article 31 the Court shall submit a report to each regular session of the AU Assembly which should include ‘the cases in which a State has not complied with the Court’s judgment’. Rule 51 of the Rules of Court notes that the article 31 report shall also include reference to the interim measures ordered by the Court and ‘[i]n the event of non-compliance with these measures by the State concerned, the Court shall make all such recommendations as it deems appropriate’ and it can also ‘invite the parties to provide it with

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