means of seizure prescribed by the laws of the Respondent State. Moreover, the petitions were sent to the competent authorities. 70. Regarding the efforts required for which the Respondent State faults the Complainant, the Commission notes that the Complainant sent not less than fifteen petitions to various authorities. As established by the Commission above, at least ten (10) of these petitions were transmitted to the competent administrative and judicial authorities in compliance with the rules prescribed by the laws of the Respondent State. Under such circumstances, it will be unreasonable and unjust to consider that the efforts made by the Complainant are insufficient. In this case, efforts regarding seizure as prescribed by the laws of the Respondent State are not quantitative but qualitative. As such, the Commission deduces that extraordinary efforts or supplementary action cannot be required from a Complainant in order to exhaust local remedies even where the threshold of action required by law has been reached. 71. The Commission notes that the inherent meaning of the term “exhaustion” refers to the conclusion of an action, the beginning of which is possible and achievable. It will therefore be illusory for averagely reasonable formalities to be required of an individual in order to conclude an action which he or she could not initiate due to a material or legal impossibility. The Commission confirms, as it did in the case of Amnesty International v. Sudan, that the spirit of the provisions of Article 56(5) is to uphold the principle of subsidiarity by providing the State the opportunity to redress violations committed in its territory.15 The philosophy underlying this rule is not therefore to impose insurmountable efforts on the Complainant. 72. The European Court of Human Rights adopts the same position when it considers for example in the case of Moreira Barbosa v. Portugal16 and Jelicic v. Bosnia-Herzegovina17 that when there is more than one potentially effective remedy, the applicant is only required to exhaust or attempt to exhaust one of such remedies. 73. In the present case, the Commission notes that having seized the judicial and administrative authorities of the Respondent State mentioned above, the Complainant reached the threshold of efforts required by the condition of the exhaustion of local remedies within the meaning of Article 56(5) of the Also see Amnesty International and Others v. Sudan Communications 48/90, 50/91, 52/91, 89/93 (2000) AHRLR 297 (ACHPR 1999) paras 31-39 and Anuak Justice Council v. Ethiopia Communication 299/05 (2006) AHRLR 97 (ACHPR 2006) 16 Case No. 65681/01, decision of 29 April 2004. 17 Case No. 41183/02, decision of 15 November 2005. 15 15