Regional systems 93 linguistic tradition, territorial connection, and political outlook. More importantly they identify themselves as a people with a separate and distinct identity. Identity is an innate characteristic within a people. It is up to other external people to recognize such existence, but not to deny it.” Consistent with the Katanga decision, the Commission decided that, in the absence of proof of massive violations of human rights guaranteed in the Charter, the people of Southern Cameroon cannot engage in secession, but may only exercise a variant of self-determination – federalism, confederacy, local government, self-government – in conformity with State sovereignty and territorial integrity.105 Article 21 affirms the right of peoples to freely dispose of their wealth and natural resources. In another 2009 ruling, related to the forced displacement of the Endorois community from their ancestral lands, the Commission found violations of both articles 21 and 22 of the Charter. It stated that “a people inhabiting a specific region within a State can claim the protection of Article 21”. The Commission held the view that “the Endorois have the right to freely dispose of their wealth and natural resources in consultation of the Respondent State”, which “bears the burden for creating conditions favourable to a people’s development”.106 Article 22 sets forth the right of peoples to economic, social and cultural development “with due regard to their freedom and identity and in the equal enjoyment of the common heritage of mankind”. Article 23 enshrines peoples’ right to peace and security. Article 24 provides that “All peoples shall have the right to a general satisfactory environment favourable to their development”. In a case involving the Ogoni community in Nigeria, the Commission ruled that “the right to a general satisfactory environment … requires the State to take reasonable and other measures to prevent pollution and ecological degradation, to promote conservation, and to secure an ecologically sustainable development and use of natural resources” and must also include “environmental and social impact studies prior to any major industrial development, undertaking appropriate monitoring and providing information to those communities exposed to hazardous materials and activities and providing meaningful opportunities for individuals to be heard and to participate in the development decisions affecting their communities”.107 The African Commission on Human and Peoples’ Rights The African Commission on Human and Peoples’ Rights is the monitoring body for the African Charter. It is composed of 11 members “chosen from amongst African personalities of the highest reputation, known for their high morality, integrity, impartiality, and competence in matters of human and peoples’ rights”. Members of the Commission serve in their individual capacities and are therefore expected to act independently while serving as commissioners. They are elected by the Summit of Heads of State and Government of the African Union for a renewable mandate of six years. The African Commission meets twice a year in ordinary sessions of 15 days each, either in its headquarters in Banjul, the Gambia, or in the territory of a State party at the latter’s invitation. It may also organize extraordinary sessions at the request of its members or of the Chair of the Commission of the African Union. Communication No. 266/2003, Kevin Mgwanga Gunme et al. v. Cameroon (2009). 105 Communication No. 276/2003, Centre for Minority Rights Development (Kenya) and Minority Rights Group International on behalf of Endorois Welfare Council v. Kenya (2009). 106 Communication No. 155/96, The Social and Economic Rights Action Center and the Center for Economic and Social Rights v. Nigeria (2001). 107