forms of seizure organised according to the circumstances and the individuals of a given case. A reading of the following Sections of the same Code reveals that the Complainant submitted her complaints following the formalities required by law since Section 135(4) (a) of the Code states that: “When the written or oral report is made by the victim of the offence, it shall be considered as a complaint....”8 Moreover, Section 135(4) (b) stipulates that “…complaints shall not be subjected to any formalities or fiscal stamps. The authorities referred to in sub-section (2) - the State Counsel, any judicial police officer or any administrative authority - shall be bound to receive the information or complaints.” 56. The Commission considers that the clarity of these provisions calls for no interpretation as to their meaning and purpose. Moreover, in civil law tradition, the general rules of procedure state that the formalities for seizing a court may range from a simple statement at the court registry on plain paper to more complex statements, including a writ of summons served by a bailiff. 57. The supporting documents accompanying the Complainant’s submission reveal that she attempted to activate local remedies by sending letters and petitions by international registered mail – including with proof of delivery, fax and Chronopost International. It appears to the Commission that in application of the Respondent State’s laws underscored above, the means by which the Complainant sought local remedies are consistent with and are not contrary to the legal provisions. As such, the argument that the Complainant failed to exhaust local remedies by not complying with the seizure requirements cannot be accepted. 58. Even though the means of seizure used by the Complainant are consistent with the law, the Respondent State however denies having received any of the several letters sent by the Complainant through the various channels indicated above. In this regard, as a general rule, a correspondence is deemed to have been delivered once the sender has evidence that the letter was actually delivered to the person or institution responsible for its transmission which, in the case under consideration, are the various postal services cited by the Complainant. It will therefore be sufficient to have a simple receipt from the postal service used - either by post or by fax, for that correspondence to be presumed delivered to the recipient. However, according to the reception theory, evidence of sending a mail only presumes that the mail was delivered until the recipient proves the contrary. 8 Cameroon Code of Criminal Procedure (27 July 2005), Section 135(4) (a). 12

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