It was further reported that during the crisis, the Rule of Law was undermined because of the lack of prosecution against perpetrators of violence. Sixty two non-nationals died and approximately between 120 000 and 200 000 were displaced. The Commission therefore raised a concern that perpetrators were not held accountable even though this was a clear demonstration of violation to human rights. This is despite the fact that South Africa is a signatory to the 1951 United Nations Convention to the Status of Refugees, 1965 United Nations Convention on the Elimination of All Forms of Racial Discrimination, 1981 African Charter on Human and Peoples' Rights and the 2005 African Commission Resolution on Ending Impunity in Africa. These international laws oblige South Africa to criminalise hate crimes. However, South Africa has not passed legislation to that effect.