Communication satisfies the requirement under Article 56(2) of the African Charter because it is: brought against the Federal Democratic Republic of Ethiopia, State Party to the African Charter; alleging violations of the provisions of the African Charter; and based on the events emanating from the enforcement of the Anti-Terrorism Proclamation No. 652/2009 enacted in 2009after the adoption of the African Charter. 101. Article 56(3) of the African Charter requires that the Communication should not be written in disparaging or insulting language. In the absence of a specific objection from the Respondent State of the Complainants records, the Commission is satisfied that the above requirement has been satisfied after examining the Complainants' submissions. 102. Article 56(4) of the African Charter requires that the Communication is not based exclusively on news disseminated through the mass media. This requirement has also been met since the Complainants relied on various documents including affidavits, court records, documentary films, amongst other supporting documents. 103. Article 56(6) of the African Charter requires that the Communication be submitted within a reasonable period of time. From the additional submissions of the Complainants under paragraph 91 above, the Complainants made a unilateral application to the Council on 15thJanuary 2013, which application was not acted upon. This was the last action recorded with regards to the procedure pursued at the domestic level. Eight months later on 4th October 2013, they lodged a complaint to the Commission having received no response from the Council. 104. Unlike other regional bodies, there are no clear guidelines on this issue of 'reasonableness' under the African Charter and as such the Commission has observed in the past that it should be assessed 'taking into account the circumstances of each caseJ? Since the delay insubmitting this Communication was not occasioned by the fault of the Complainants but that of the Council failure to act this Communication has been submitted within a reasonable time. 105. Article 56(7) of the African Charter requires that the Communication should not have been settled before other international bodies. The Commission notes that nothing in the facts as well as the parties' submissions reveal a violation of this provision and therefore finds it satisfied as well. 106. Consequently, the Conunission is satisfied that the Complainants have fulfilled the requirements under Article 56(1), (2), (3) (4), (6) and (7) of the African Charter. In this regard, the Commission will proceed to analyse the arguments of both parties with regards to the requirement under Article 56(5) of the African Charter on the exhaustion of local remedies, which has been particularly contested by the Respondent State. 107. Article 56(5) of the African Charter requires that the Complainant should exhaust local remedies unless it is obvious that the procedure is unduly prolonged. The requirement to exhaust local remedy is a precondition that must be satisfied before finding a Communication Admissible.s? In Zimbabwe Laurfers for Human Rights & As~ ~--~ )1> '0>, \ " See 1m example Communication No. 300/05 _ Socio-economic Rights and Accoun tability Proje {§.~ge"a (2:~) ACHPR. 20 See generally the following Communications: Communication No. 284/03 -- Zimbabuie Rights & Associated Newspaper of Zimbabioe v. Zimbabwe (2009) ACHPR; Communication 221/9 i!yers for Human 0 udioe v, @haYt~ rg ""J.. . I ~ ~ ~\ r; .; '" // If -1 .~})"'" IC!'" "''''RIO'''''' At;,'5 / S's ...... U'" } ( )f0.\fME f' 0-- C, / .. '

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