the case of Dawda K Jawara vs. The Gambia44 that the rationale 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, having reviewed the Communication and supporting documents, the African Commission observed in particular that: (i) the supplementary facts presented in addition to the initial Complaint are indicated to have been gathered from an account provided by the Complainant of the Victim's personal experiences which formed the basis of the alleged human rights violations in the Communication; (ii) the Communication is also supported by a signed written testimony of the Complainant dated 12 December 2012,45 and medical reports that reflect the injuries claimed to have been inflicted on him during the alleged beatings in detention.46 74. Consequently, the facts of this Communication are not primarily nor exclusively based on news disseminated through the mass media, but rather on alleged personal experiences of the Complainant pertaining to his alleged: arbitrary detention; torture, cruel, inhuman or degrading treatment or punishment; deprivation of access to a lawyer of choice; inability to challenge his arbitrary detention and attendant deprivation of procedural safeguards; denial of freedom of expression; and denial of protection from the Respondent State from the violation of his rights by taking requisite measures; in violation of the referenced provisions of the African Charter. 47 Therefore, in the Commission's view, the Communication meets the requirement of Article 56(4) of the African Charter. 75. Article 56(5) of the African Charter states that "Communications ... received by the Commission shall be considered if they ... are sent after exhausting local remedies, if any, unless it is obvious that this procedure is unduly prolonged." 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 exhausted.48 76. The African Commission has expounded on this principle in its jurisprudence49 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"50, and that "the internal remedy 44 Fn 13 above, paras 23-27. 45 Appendix 2 to the Complaint. Also attached to the Admissibility submission. 46 Appendix 1 to the Complaint. Also attached to the Admissibility submission. See, paras. 1-17 of the supplemental information, as well as paras. 6, 8-9 of the Admissibility submission of the ~~t. ~ 1 48 See Article 19 vs. Eritrea, fn 14 above, para 45. ~~ "', ~ 49 There is a plethora of decisions of the Commission on this subject. See generally the Com~i atroJJ✓'Ofoe·ci~ib'ns on Communications of the African Commission on Human & Peoples' Rights: 1994-2001 ', (2002) lnstitule for man , s & Development, p.429-430; Decisions of the African Commission on Human & Peoples' Rights on Corl'ffmmi tio9s. 2002-20 7'"1 (2008) Institute for Human Rights & Development, p.421-424. : , _. / -;;J 50 Communication 242/01- Institute of Human Rights and Development in Africa & lnterights vs. , ~ ~; ?J 47 ,,ut/ • t. -.-. ;, ":-~ ·'%.s ......._ ~ , is,.,"' o,._ •i • F< LJ,·1 • • ( ,, ~'\*f E"l \)\.. \'' / I/