172 Nyman-Metcalf and Papageorgiou/Implementation of rulings by regional courts From the above, it becomes evident that human rights form part of European law in a wide sense and permeate decisions of regional as well as national organs. What perhaps is the main characteristic of the European legal system is the well-developed interplay between the regional and the national, with national organs being obliged to implement European decisions and having a set framework for doing so, with oversight by the European organs. 2.2 Africa The African continent is home to many regional integration organisations. The African Charter on Human and Peoples’ Rights (also called the Banjul Charter) was adopted in 1981 by the then Organization for African Unity (OAU) and entered in force in 1986.15 Several regional integration instruments in Africa have been inspired by European counterparts, but the Charter shows examples of both different and more innovative rights.16 Nevertheless, it has not yet reached the level of impact of the European system and its monitoring system is less innovative than the substantive rights. There still appears to be a significant amount of scepticism among African leaders concerning ‘interference’ in internal affairs. Reforms of the human rights system have aimed at improving the impact of the human rights provisions, as the history of the regional system shows that this has been the weak point within the system. For instance, the African Commission on Human and Peoples’ Rights (African Commission),17 which was set up in 1987, was vested with many competences but monitoring procedures, reporting requirements, inter-state and individual complaints procedures were not well developed or efficient.18 Eventually, the African Commission started formulating recommendations in which it urged, requested or appealed to member states to undertake actions in order to enforce its decisions.19 The African Court on Human and Peoples’ Rights (African Court) was established by the Protocol to the African Charter on Human and Peoples’ Rights on the Establishment of an African Court on Human and Peoples’ Rights (African Court Protocol), adopted by the OAU in June 1998. The Protocol came into force on 25 January 2004 and the Court started operating in 2008. It is based in Arusha, Tanzania. It 15 M Nowak Introduction to the international human rights regime (2003) 203-214. For example, the African human rights system was the first to include the right to a satisfactory environment as a human right. This right was interpreted in the Ogoniland case (Communication 155/96 The Social and Economic Rights Action Centre and another against Nigeria). See M van der Linde & L Louw ‘Considering the interpretation and implementation of article 24 of the African Charter on Human and Peoples’ Rights in light of the SERAC communication’ (2003) 3 African Human Rights Law Journal 170. 17 The African Commission on Human and Peoples’ Rights was established by the African Charter, and inaugurated on 2 November 1987 in Addis Ababa, Ethiopia. The Commission’s Secretariat is located in Banjul, The Gambia. 18 Nowak (n 15 above) 203–214. 19 Van der Linde & Louw (n 16 above) 181 16