61. In such circumstances and when they are allowed to withdraw, states should be required to give prior notice. The requirement of notice is necessary in the instant case especially as the declaration pursuant to Article 34(6) once made constitutes not only an international commitment on the part of State, but more importantly, creates subjective rights to the benefit of individuals and groups. 62. In the view of the Court, the provision of a notice period is essential to ensure juridical security by preventing abrupt suspension of rights which inevitably impact on third parties, in this case, individuals and groups who are rightsholders.7 This is more so as the Protocol is an implementing instrument of the Charter that guarantees the protection and enjoyment of human and peoples' rights contained therein as well as in other relevant human rights instruments. The suddenness of a withdrawal without prior notice therefore has the potential to weaken the protection regime provided for in the Charter. 63. In a matter similar to the one at hand, the Inter-American Court of Human Rights made a determination on the basis of the principle of legal certainty by holding in the case of lvcher Bronstein v Peru that: "A unilateral action by a State cannot divest an international court of jurisdiction it has already asserted; [where] a State [is allowed to] withdraw its recognition of the Court's contentious jurisdiction, formal notification would have to be given one year before the withdrawal could take effect, for the sake of juridical security and continuity." 8 7 See Frans Viljoen International Human Rights Law in Africa (2007) Oxford at page 256 and Laurence R. Heller, Terminating Treaties in Duncan Hollis (ed.) The Oxford Guide to Treaties Oxford University Press, 2012 at pages 634-649. 8 lvcher Bronstein v Peru at paragraph 24(b). 15