with. 95. In relation to Article 56(4) of the African Charter, the Commission has explained in the case of Dawda K Jawara vs. The Gambia 49 that the raison d'?tre for this requirement is to determine whether the facts of a Communication are based "exclusively" on news disseminated through the mass media, without more. Consequently, the Commission has perused the appendices to the Communication and observed that they contain relevant official documents that are not collected from the mass media. Therefore, in the Commission's view, the Communication meets the requirement of Article 56(4). 96. Regarding Article 56(5) of the African Charter, the Commission notes Tanzania's contention that the Victims failed to pursue domestic remedies in the municipal courts of the Respondent States, including Tanzania. The exhaustion of local remedies rule, codified under Article 56(5) of the African Charter, is a principle under international law of permitting a State to have an opportunity to redress the wrong that has occurred there, within the framework of its own domestic legal order, before its international responsibility is called into question at the international level. It is a well established rule of customary international law that before international proceedings are instituted, the various remedies provided by the State should have been exhausted50 . 97. The Commission has expounded on this principle in its jurisprudence 51 and has held that "the generally accepted meaning of local remedies, which must be exhausted prior to any communication/complaint procedure before the African Commission, are the ordinary remedies of common law that exist in jurisdictions and normally accessible to people seeking justice"52 , and that "the internal remedy [to] which Article 56(5) refers entails remedy sought from courts of a judicial nature..."53 . Furthermore, the Commission's Information Sheet No. 354 , also states that "[t]he author [of a Communication] must have taken the matter to all the available domestic legal remedies. That is, he or she must have taken the case to the highest court of the land." 98. The import of the foregoing is that Article 56(5) contemplates the exhaustion of the ordinary remedies of common law that exist in the judicial courts of the Respondent States. 99. Notwithstanding this general rule, the African Commission has held in previous Communications that: "... the local remedies rule is not rigid. It does not apply if: local remedies are inexistent; local remedies are unduly and unreasonably prolonged; recourse to local remedies is made impossible; from the face of the complaint there is no justice or there are no local remedies to exhaust, for example, where the judiciary is under the control of the executive organ responsible for the illegal act; and the wrong is due to an executive act of the government as such, which is clearly not subject to the jurisdiction of the municipal courts."55 100. Furthermore, the Commission has held that: [Article 56] of the African Charter requires that Complainants exhaust local remedies before the Commission can take up a case, unless these remedies are as a practical matter unavailable or unduly prolonged... [and that] the Commission has never held the requirement of local remedies to apply literally in cases where it is impractical or undesirable for the Complainant to seize the domestic courts in the case of each violation."56 [Emphasis added]. 101. Similarly, the European Court of Human Rights has held, in cases "where requiring the applicant to use a particular remedy would be unreasonable in practice and would constitute a disproportionate obstacle to the effective exercise of the right of individual application under Article 34 × Individual applications. The Court may receive applications from any person, nongovernmental organisation or group of individuals claiming to be the victim of a violation by one of the High Contracting Parties of the rights set forth in the Convention or the Protocols thereto. The High Contracting Parties undertake not to hinder in any way the effective exercise of this right. of the Convention", that the applicant is dispensed from that requirement.57 102. The Commission notes that the fora for exhausting local remedies contemplated under Article 56(5) of the Charter do not include the Tribunal, which is a supra-national court and sub-regional treaty body 58 and not a "judicial court" of any of the Respondent States. As a result, it would be incorrect to state that "domestic remedies" could not be exhausted as a result of the suspension of the Tribunal. 103. Nevertheless, the Commission is convinced by the argument of the Complainant that Article 56(5) cannot be interpreted to contemplate that the Victims/Complainant would be required to pursue local remedies, if at all there is any, in all of the fourteen (14) Respondent States before approaching the Commission. On this issue, the Commission is guided by its jurisprudence in cases where it has, in view of the vast and varied scope of the violations alleged and the large number of victims involved, held that local remedies need not be exhausted because it would involve seizing the domestic courts in respect of each violation and/or victim, which would in effect unduly prolong the process of exhausting local remedies in such cases.59 11