incarcerated,14 lay in law,15 indigent;16 and the time required to reflect on the advisability of seizing the Court.17 The Court has also taken into account whether an applicant has pursued a review process and the time spent doing so.18 37. As the record shows, the Applicant exhausted local remedies on 17 March 2014 being the date of the Court of Appeal’s judgments in his appeal. The Applicant subsequently filed his Application before this Court on 1 September 2016. The Court should, therefore, assess whether the period of two (2) years, five (5) months and fifteen (15) days that elapsed between these two events is reasonable within the meaning of Article 56(6) of the Charter. 38. In the instant case, the Court notes that at the time of filing his Application, the Applicant was incarcerated, and on death row. It is also clear, from the record, that he was lay and self-represented when filing his Application. Additionally, it is obvious that the Applicant, given his situation, required some minimum time to reflect on the opportuneness and preparation of his Application. Finally, this Court also observes that, on 2 April 2014, the Applicant filed an application for review of the Court of Appeal’s judgment which was pending at the time the present Application was lodged. As such, the Applicant had to spend some time awaiting the outcome of the application for review, and to decide on the opportuneness and preparation of the present Application. 14 Diocles William v. United Republic of Tanzania (merits) (21 September 2018) 2 AfCLR 426, § 52 and Thomas v. Tanzania (merits), ibid, § 74. 15 Christopher Jonas v. United Republic of Tanzania (merits) (28 September 2017) 2 AfCLR 101, § 54 and Amir Ramadhani v. United Republic of Tanzania (merits) (11 May 2018) 2 AfCLR 344, § 83. 16 Nguza Viking (Babu Seya) and Johnson Nguza (Papi Kocha) v. United Republic of Tanzania (merits) (23 March 2018) 2 AfCLR 287, § 61 and Amir Ramadhani v. United Republic of Tanzania (merits), ibid, § 83. 17 Igola Iguna v. United Republic of Tanzania, ACtHPR, Application No. 020/2017, Judgment of 1 December 2022 (merits and reparations), § 35 and Zongo and Others v. Burkina Faso (preliminary objections), supra, § 122. 18 John Lazaro v. United Republic of Tanzania, ACtHPR, Application No. 003/2016, Judgment of 7 November 2023, § 49; Werema Wangoko v. Tanzania (merits), § 49; Alfred Agbesi Woyome v. Republic of Ghana, ACtHPR, Application No. 001/2017, Judgment of 28 June 2019 (merits), §§ 83-86. 12

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