a case-by-case approach to assessing what constitutes reasonable time, taking into account the particular circumstances of each case.18 The Court has taken into consideration the following circumstances, inter alia, that impact on the reasonable time within which to file an application with the Court: the incarceration of the Applicant, the fact that the Applicant is lay, does not have legal aid,19 is indigent, illiterate, is not aware of the existence of the Court, was being intimidated and fearing reprisals20 as well as the exhaustion of extraordinary remedies.21 55. The Court recalls that it has held that local remedies were exhausted as regards the alleged human rights violations relating to Laws No.2018-16 of 04 January 2018 on the status of the judiciary, Law No.2018-02 of 2 July 2018 of the HJC, Law No.2019-40 of 7 November 2019 on the revision of the Constitution and Law No. 2019-43 of 15 November 2019 on the Electoral Code, which were declared to be constitutional, respectively by Decisions DCC 18-141 of 18 June 2018, DCC 18-142 of 18 June 2018, DCC 19-504 of 6 November 2019 and DCC 19-525 of 14 November 2019 of the Constitutional Court. 56. The Court considers that the count of a reasonable time for its seizure starts from the dates the Constitutional Court issued its decisions, that is, 18 June 2018, 6 November 2019 and 14 November 2019. Between these dates and that of the filing of the Application, that is, 17 September 2020, two (2) years, two (2) months, twenty-nine (29) days, ten (10) months and ten (10) days Beneficiaries of the late Norbert Zongo and Others v Burkina Faso, (21 June 2013) (Preliminary Objections) 1 AfCLR 195, § 121; Alex Thomas v United Republic of Tanzania (20 November 2015), (Merits), 1 AfCLR482, § 73. 19 Alex Thomas v. Tanzania (Merits), op.cit. § 73; Christopher Jonas v. Tanzania (Merits) op.cit. , § 54, Ramadhani v. Tanzania, (11 May 2018), (Merits), 2 AfCLR 344, § 83. 20 Association pour le progrès et la défense des droits des femmes maliennes et Institute for Human Rights and Development in Africa v Republic of Mali (11 May 2018) (Merits)) 2 AfCLR 380, § 54. 21 Armand Guéhi v. Tanzania (Merits and Reparations) op.cit, § 56; Werema Wangoko v. United Republic of Tanzania (Merits) (7 December 2018), 2 AfCLR 520, § 49; Alfred Agbesi Woyome v. Republic of Ghana, (Merits and Reparations) (28 June 2019), 3 AfCLR 235, §§ 83-86. 18 19

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