discretionary'.35 If it does not satisfy these criteria then it will not have to be exhausted. 105.In relation to the Police Administration Committee there is very little information provided by the State. No information is provided regarding the legal basis on which it was established, the processes before the committee, including whether there are procedural guarantees, and the kinds of remedies that it is able to provide. For these reasons, in addition to the submission by the Complainant that neither himself nor his legal representative had been informed about this process and the absence of proof to the contrary, the Commission finds that this would not have resulted in an effective remedy. In any case the procedure before the NHRC is not a judicial procedure, as the Commission has held before, and thus processes before it need not be exhausted.36 106.On the basis of these conclusions, the Commission thus finds that the Complainant did not have to exhaust local remedies, as they were not available, effective and sufficient. 107. Article 56(6) requires that a Complaint must be" submitted within a reasonable period from the time local remedies are exhausted or from the date the Commission is seized of the matter". The Complainant notes that in the jurisprudence of the Commission, where remedies were found to be unavailable, ineffective or insufficient, timeliness would be assessed from the time of the Complainant's notice of the unavailability, ineffectiveness or insufficiency of the remedies, 37 noting that the relocation of the Complainant to another jurisdiction; the complexities of getting representation and challenges of communication systems in Africa are factors which are relevant in relation to timelines.38 The Complainant submits that he filed the complaint approximately 13 months after he was released from prison and 11 months after he fled to Kenya, indicating that he had in addition found it challenging to settle in Kenya. 108. The Respondent State to the contrary argues that because the Complainant had remained free in his country for two months after his arrest and thereafter of his free will left the country, the Complainant had not provided a manifestly reasonable justification for this delay. In response the Complainant states that the State did not respond with adequate specificity as to the factors which determine whether there was a reasonable period, thus failing to demonstrate