, ,0008:?* without merit since they could have mandated counsel or any other person they trust to file a claim in the domestic courts on their behalf. 63. The Respondent State supports its aforementioned position with the decisions of the Commission in Zitha v Mozambique and Givemore Chai (Represented by Gabriet Shumba) v Republic of Zimbabwe where the Commission has ruled that where national laws do not require physical presence of a claimant, then the claimant should exhaust local remedies using Counsel. 64. The Applicants state that they have not referred the matter to the national jurisdiction of the Respondent State because they do not have valid passports to travel to the Republic of Rwanda to exhaust local remedies. They aver that local remedies are 'not practical' because the courts in the Respondent State are not independent. 65.The Court notes that pursuant to Rule 40 (5) of the Rules an application filed before the Court shall meet the requirement of exhaustion of local remedies. 66.The rule of exhaustion of local remedies reinforces the primacy of domestic courts in the protection of human rights yls-ii,-vis international human rights bodies. lt aims at providing states the opportunity to deal with human rights violations occurring in their jurisdiction before such bodies are called upon to determine the responsibility of the States for such violations.la laApplicationNo.006/2012.Judgmentof26tOSl2O17 (Merits). AfricanCommissiononHumanandpeoples' Rights v Republic of Kenya (African Commission v Kenya (Merits)) Sg 93-94; 16