r, r.J 6�!j,E,� p,.CHP/1 <nuw. • Human Rights our Collective Responsibihty Human and Peoples' Rigtits the latter that led to and forms the basis of the former. The criminal case was already considered by the JCPC, the court of last resort, which restored the conviction and sentence. The Complainant attempted to have the criminal and disciplinary cases re-opened in light of alleged exculpatory evidence and underhand machinations that allegedly led to his conviction and subsequent disbarment. Those attempts were dismissed on account of the issue of litigating in person in respect of which an appeal to the JCPC the apex court was declined. 90. In the circumstances, the Commission considers that the Complainant exhausted local remedies in respect of the criminal case and the disciplinary action taken against him as a barrister. The rest of the issues are incidental to the criminal case, the disciplinary action and the issue of the right to litigate in person. Accordingly, the Commission is inclined to find, and holds that for all purposes the Complainant exhausted local remedies. It must be observed however, that in so finding, the Commission does not purport to prejudge the merits of the issues at hand. The issue as to whether provisions of the Charter have been violated will be considered subsequently at the merit stage, if the Communication satisfies the remaining admissibility conditions. 91. Regarding Article 56(6) of the Charter which requires that communications must be submitted within reasonable time after exhaustion of local remedies, the Commission recalls its jurisprudence that in determining whether a complaint has been submitted within reasonable time, each case has to be considered on its own circumstances.17 In the present Communication the critical point at which local remedies were exhausted is 12 July 2013 when the JCPC, the apex judicial authority for the Respondent State, declined to entertain the relevant appeal by the Complainant. It is about two months from 12 July 2013 to 18 September 2013 when the Complainant submitted the present Communication. The Commission is satisfied that a period of two is within reasonable time and accordingly this Communication satisfies Article 56(6) of the Charter. 92. Lastly, whereas the Complainant first attempted to submit the complaint to the African Court on Human and Peoples' Rights, the latter declined jurisdiction as the Respondent State has not ratified the necessary instrument to be impleaded before that Court. There is nothing suggesting that he approached an.o �:,::t �::::::::..... r .,<c- ' 1 7 Cornmunicat10n 308/0:> - Micha1•/ M,.1_:,m, 11 7,iml,al,wl' (2008) ACHPR para. 109. ... .. Atric.a'l• ' Unio'l I Page 21 of 45 African Commission on Human and P 31 Bijilc Annex Layout, Kombo West Coast Re Phone: (220) 230 4361 Fax: (220 Email: au-banjul@africa , _ } 1) "'_\, ,>"'�; 1 ,____ icA1 ._ 0::_�;;; _; '· 7 --.;:;;�-� h•tps:/achpr.au.int,O O a