96 PROMOTING AND PROTECTING MINORITY RIGHTS can provide an alternative source of information and may assist the commissioners in asking questions of the State about the situation of minorities and drafting their concluding observations. Complaints from individuals and NGOs The African Charter does not explicitly speak of “individual and NGO complaints” but uses the term “other communications” to distinguish these communications from those submitted by States.117 In practice, however, any individual or organization may submit a communication; one needs not be African, a resident of the State complained against, or even a victim, and communications have been filed by international organizations and individuals based outside Africa. Individual members of a minority may complain on their own behalf or on behalf of the group to which they belong. Complainants need not have the permission of the alleged victim(s) in order to submit a communication. This permits NGOs or others to file complaints even when all of the victims may not be known. However, NGOs should be responsible and put the safety of the alleged victims first, which includes seeking the permission of alleged victims to submit a communication; this can be vital, especially if the cooperation of the victim will later be necessary. The Commission has stated that “in a situation of grave and massive violations, it may be impossible to give a complete list of names of all the victims. It will be noted that article 56(1) demands simply that communications should indicate the names of those submitting and not those of all the victims of the alleged violations.”118 Every communication should be as detailed as possible, comprehensive and verified as far as possible. Where possible, NGOs should submit statements or affidavits from the author(s) of the complaint, witnesses, family members and others who have relevant information about the specific issues raised. If the authorities are involved, information such as the number and kind of police or security services, or details of any arrest or search should be included. In addition, texts of relevant laws and directives, legal judgements and copies of any publications or documents which may have been seized should be annexed to the communication. If the situation does not obviously constitute a human rights violation, the applicant should try to refer to relevant international opinions to support the claim that the act violates the norms of the African Charter. Admissibility criteria Seven criteria set forth in article 56 of the Charter must be satisfied for a complaint to be considered on its merits by the Commission: • The communication must not be anonymous, although it may be requested that the identity of the author not be disclosed. For practical reasons, the Commission must be able to contact the author. • The communication must allege violations of rights that are protected by the Charter and must be compatible with the Constitutive Act. This provision prohibits any claim for secession, which would be counter to the Constitutive Act’s reaffirmation of the territorial integrity of States. • The communication must not have manifestly political motivations or be written in “disparaging or insulting language”. • The communication should not be based exclusively on media reports, but reliance to some degree on the media is permissible. The complainant should attempt to verify the Detailed provisions for the latter are set out in articles 47-54. 117 Communications Nos. 54/91, 61/91, 96/93, 98/93, 164/97-196/97 and 210/98, Malawi Africa Association and Others v. Mauritania (2000), para. 79. The Commission reiterated this finding in its Communication No. 266/03, Kevin Mgwanga Gunme et al. v. Cameroon (2009), para. 67. 118