8 Anyangwe/Extrajudicial killings of women in Africa State is established by showing that it condones a pattern of abuse through pervasive non-action. Under these circumstances, therefore, the State would be in breach of its international human rights obligations. The act of the non-state actor being the act of a private person is initially not directly imputable to the State. However, the act does lead to international responsibility of the State under the rules of international law not because of the act itself but because the State failed in its due diligence obligation to prevent the violation or to respond to it as required by human rights law.20 In order to show that extrajudicial killing has been committed it is not necessary, as in murder under municipal criminal law, to determine the guilt of the non-state actor or his intention. Likewise, in mass-actorkilling cases, it is not necessary to identify the actual specific individual perpetrator by whose hand the victim met his death. It is sufficient simply to demonstrate that public authorities have supported or condoned or tolerated the violation of the right to life.21 Thus, although an act by a private individual or a non-state actor would ordinarily not be directly imputable to the State, it can nevertheless generate responsibility of the State not because of the act itself, but either because of lack of due diligence on its part to prevent the violation, or because it did not take the necessary steps to provide the victims with reparations. That is the tenor of the ruling of the African Commission in Aminu v Nigeria; Social and Economic Rights Centre v Nigeria; and Sudan Human Rights Organisation and Another v Sudan.22 This jurisprudence is consistent with that of the Inter-American human rights system.23 It is also in line with the view articulated by the UN Human Rights Committee and the UN Special Rapporteur.24 2.4 Statistics Extrajudicial killing of women is an extreme form of violence against women by men or by other women. Estimating the actual occurrence of this phenomenon is difficult in part because killings of this nature tend to be statistically subsumed under the generic legal rubric of homicide and is thus largely hidden. Potential sources of incidents involving the killing of women are self-reports by family members, reports by friends from phone-ins, records of social workers, and records of police and health services. These sources may record the number of women who have been murdered. But data from these sources would be problematic where it does not reflect gender discrepancies or differentiate between 20 Valesquez Rodriguez v Honduras IACHR (29 July 1989) Ser C No 4. Tradesmen v Colombia IACHR (2004) Ser C No 109. 22 Aminu v Nigeria (2000) AHRLR 258 (ACHPR 2000); Social and Economic Rights Action Centre v Nigeria (2001) AHRLR 60 (ACHPR 2001); Sudan Human Rights Organisation & Another v Sudan (2009) AHRLR 135 (ACHPR 2009). 23 Valesquez v Honduras (n 20 above); Tradesman v Colombia (n 21 above). 24 General Comment 31 of 26 May 2004; ‘Report of the Special Rapporteur’ 2004 (n 1 above) paras 72-73; ‘Report of the Special Rapporteur’ 2010 (n 12 above) paras 45-47; ‘Report of the Special Rapporteur on Violence against Women, its Causes and Consequences’ (1996), Doc. E/CN.4/1996/53, para 30-33. 21