-1969. The Court recalls in this regard that the African Commission on Human and Peoples' Rights (hereinafter referred to as "the Commission"), when considering Communication No. 284/2003 (2009), has established the criteria for what would amount to disparaging or insulting language within the meaning of the two provisions cited above, when used in an Application. 70. The Commission has stated that: "The operative words in Article 56(3) are disparaging and insulting and these words must be directed against the State Party concerned or its institutions or the African Union. According to the Oxford Advanced Dictionary, disparaging means to speak slightingly of ... or to belittle ... and insulting means to abuse scornfully or to offend the self-respect or modesty of ... "2 Again, according to the Commission: "In determining whether a certain remark is disparaging or insulting and whether it has dampened the integrity of the judiciary, the Commission has to satisfy itself whether the said remark or language is aimed at unlawfully and intentionally violating the dignity, reputation and integrity of a judicial official or body and whether it is used in a manner calculated to pollute the minds of the public or any reasonable man to cast aspersions on and weaken public confidence on the administration of justice. The language must be aimed at undermining the integrity and status of the institution and bring it into disrepute[... ]"3 . 2 African Commission on Human and Peoples' Rights, Zimbabwe Lawyers for Human Rights & Associated Newspapers of Zimbabwe v. Zimbabwe, Communication n° 284/2003, 3 April 2009, paragraph 88 (Frenc . version). 3 Id., paragraphe 91. 4 19

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