303 © The Author(s) 2019
P. Engstrom (ed.), The Inter-American Human
Rights System, Studies of the Americas,
https://doi.org/10.1007/978-3-319-89459-1_12
CHAPTER 12
Impact in the African and Inter-American
Human Rights Systems: A Perspective
on the Possibilities and Challenges
of Cross-Regional Comparison
Frans Viljoen
F. Viljoen (*)
Centre for Human Rights, University of Pretoria, Pretoria, South Africa
e-mail: Frans.viljoen@up.ac.za
INTRODUCTION
There are two main approaches to a cross- or inter-regional comparison of
the impact of the Inter-American and the African human rights systems.
The comparison may treat the two systems as distinct or discrete, and aim
to draw ‘lessons’ or useful insights from one system to infuence (or
‘impact on’) the other system. One may, for example, analyse the charac-
teristics of the ‘precautionary’ or ‘provisional’ measures mechanism, as
developed by the Inter-American Commission on Human Rights
(IACHR) and Inter-American Court of Human Rights (IACtHR), to
serve as guide for the strengthening of this mechanism by the African
Commission on Human and Peoples’ Rights (African Commission) and