The African Commission noted in the Amnesty International v Sudan²⁵ case, that “ratification obliges a state to diligently undertake the harmonization of its legislation to the provisions of the ratified instrument”. Article 1 of the ACHPR directs States parties to “adopt legislative or other measures to give effect to the rights protected under the Charter”. It further stated that “Article 1 of the Charter confirms that the government has bound itself legally to respect the rights and freedoms enshrined in the Charter and to adopt legislation to give effect to them”.²⁶ Regional African Standards Article 4 (0) of the Constitutive Act of the African Union²⁷ sets out that members of the African Union (AU) will function in accordance with the principle of respect for sanctity of human life, condemnation and rejection of impunity and political assassination, acts of terrorism and subversive activities. Principle (m) of the same article demands a respect for democratic principles, human rights, and the rule of law and good governance. Zimbabwe in signing and ratifying this Constitutive and being a member of the African Union, pledged to adhere to such principles. The African Charter,²⁸ in Article 4 states: Human beings are inviolable. Every human being shall be entitled to respect for his life and the integrity of his person. No one may be arbitrarily deprived of this right”. ²⁹ Article 7 of the same Charter guarantee one's right to be heard before the court and to be presumed innocent until proved guilty. The Resolution on the fight against Impunity in Africa³⁰ urges State Parties to the African Charter to: comply with their obligations to investigate serious human rights violations, and hold perpetrators accountable in accordance with applicable regional and international human rights standards; take the necessary legislative and other measures to put an end to impunity and ensure that all the perpetrators of serious human rights violations are prosecuted; adopt necessary laws, policies and mechanisms to guarantee the rights to justice, truth and reparation for victims of serious human rights violations and international crimes. Zimbabwe's Legal Framework The Zimbabwe Constitution³¹ enshrines the country's founding values and principles including the rule of law, fundamental human rights and freedoms, recognition of the inherent dignity and worth of each human being, recognition of the equality of all human beings, and good governance. It further elaborates on the principles of good governance, “which bind the State and all institutions and agencies of the government at every level”, to include “transparency, justice, accountability and responsiveness”. ²⁵ 48/90-50/91-89/93 Amnesty International Comite Loosli Bacherlard, Lawyers Committee for Human Rights Association of Members of the Episcopal Conference of East Africa/Sudan, available at: http://www.achpr.org/commuications/decision/48.90-50.91-89.93/. ²⁶ Ibid at para 40. ²⁷ Organization of African Unity (OAU), Constitutive Act of the African Union, 1 July 2000 ²⁸ The African Charter on Human and Peoples‟ Rights (adopted 27 June 1981, entered into force 21 October 1986) (1982) 21 ILM 58 (Banjul Charter). ²⁹ Organization of African Unity (OAU), African Charter on Human and Peoples' Rights ("Banjul Charter"), 27 June 1981, CAB/LEG/67/3 rev. 5, 21 I.L.M. 58 (1982). ³⁰ Resolution on the fight against impunity in Africa - ACHPR/Res. 344(LVIII) 2016. ³¹ Constitution of Zimbabwe Amendment (No. 20) Act, 2013 [Zimbabwe], 22 May 2013. Anti-Impunity Report 15