application for review of the Court of Appeal’s decision was dismissed on 19 March 2015. Given that the Court of Appeal is the highest Court in the Respondent State, the Court finds that the Applicant exhausted local remedies before filing her Application. 44. As the Court has established: “…the reasonableness of the timeframe for seizure depends on the specific circumstances of the case and should be determined on a case-by-case basis.”9 In this connection, the Court has considered as relevant factors, the fact that an applicant is incarcerated,10 being lay in law without the benefit of legal assistance,11 their indigence, the time taken to pursue the review remedy before the Court of Appeal, or to access the documents on file,12 intimidation and fear of reprisal,13 the recent establishment of the Court, the need for time to reflect on the advisability of seizing the Court and determine the complaints to be submitted.14 45. The Court has previously stated that it is not enough for applicants to simply plead that they were incarcerated, are lay or indigent, for example, to justify their failure to file an Application within a reasonable period of time.15 It is also important for all Applicants to demonstrate how their personal situations prevented them from filing their applications within a reasonable period. 46. The Court recalls that the present Application was filed on 24 April 2019. The Respondent State’s Court of Appeal rendered its judgment dismissing the Applicant’s appeal on 11 March 2013. However, the record confirms that 9 The beneficiaries of the late Norbert Zongo Abdoulaye Nikiema alias Ablasse, Ernest Zongo and Blaise IIboudo v. Republic of Burkina Faso (merits) (24 June 2014) 1 AfCLR 219, § 92. See also, Alex Thomas v. Tanzania (merits), § 73. 10 Diocles William v. United Republic of Tanzania (merits) (21 September 2018) 2 AfCLR 426, § 52; and Alex Thomas v. Tanzania (merits), § 74. 11 Alex Thomas v. Tanzania (merits), § 73; Christopher Jonas v. United Republic of Tanzania (merits) (28 September 2017) 2 AfCLR 101, § 54; Amir Ramadhani v. United Republic of Tanzania (merits) (11 May 2018) 2 AfCLR 344, § 83. 12 Nguza Viking and another v. Tanzania (merits), § 61. 13 Association Pour le progress et la Defense des droits des Femmes Maliennes and the Institute for Human Rights and Development in Africa v. Mali (merits) (11 May 2018) 2 AfCLR 380, § 54. 14 Norbert Zongo and Others v. Burkina Faso (preliminary objections), § 122. 15 Layford Makene v. United Republic of Tanzania¸ ACtHPR, Application No. 028/2017, Ruling of 2 December 2021 (admissibility), § 48. 14

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