African Charter. The Commission concludes that the Complainant did not only seize the competent authorities following the required formalities but also exceeded the efforts required to activate local remedies. 74. The Respondent State also contends in its submission to the Commission that the Complainant’s husband should have come in person to seize the Cameroonian authorities. On this issue, the Commission has already noted above that under Cameroonian law complainants are not obliged to be physically present to be able to lodge a valid complaint. This position stipulated in the law of the Respondent State is in line with the African Charter and the jurisprudence of the Commission. 75. In fact, the issue of the need for a Complainant’s physical presence in the territory of the Respondent State at the time of the attempt to exhaust local remedies has been settled by the Commission. In the case of Abubakar v. Ghana18 and Amnesty International v. Zambia19 for example, the Commission consistently considers that several reasons, such as political exile, fear for one’s life – such as following death threats as it is in the present case, or deportation may prevent a Complainant from being in the territory of the Respondent State at the time he or she seizes the local courts. 76. Under such circumstances, the Commission is of the view that in the present case, it would be unreasonable and illogical to require that the Complainant’s husband, whereas he and his family were receiving constant death threats including through phone calls, returns to Cameroon and lodge a complaint, where he previously experienced serious attacks on his person.20 Such an approach would be risky and superfluous given that it is not required by law. 77. At this stage, the Commission notes that local remedies existed at the time of the events both in theory and in practice. The Commission also notes that the Complainant seized the competent authorities in accordance with the formalities prescribed by law. The Commission however notes that the said remedies were not available to the Complainant, and that the lack of action by the authorities of the Respondent State rendered such remedies inaccessible. Moreover, the Commission is satisfied that the efforts made by the Complainant are sufficient. The Commission concludes that the remedies rendered inaccessible were not available, even if they existed, and that the Complainant actually attempted to exhaust them. Communication 103/93 (2000) AHRLR 124 (ACHPR 1996). Also see Jawara para 35. Communication 212/98 (2000) AHRLR 325 (ACHPR 1999). 20 See Abubakar v. Ghana; Amnesty International v. Zambia. See in particular Rights International v. Nigeria Communication 215/98 (2000) AHRLR 254 (ACHPR 1999) para 24. 18 19 16