to reject a Communication because some aspects of it are based on news disseminated through the mass media. For this reason, the African Commission believes that the present Communication meets Complainants the requirements of Article 56(4) of the African Charter. 107. Article 56(5) of the African Charter on its part requires that Communications brought under Article 55 of the African Charter shall be considered only if they AC HP R “are sent after the exhaustion of local remedies, if any, unless it is obvious that this procedure is unduly prolonged”. The relevance of Article 56 (5) of the African Charter is to ensure that international mechanisms are not substitutes for domestic implementation of human rights, but should be seen as tools to assist the domestic authorities to develop a sufficient protection of human rights in their territories. 108. The African Commission notes that the submissions of the Complainants that Kobedi‟s case has been dealt with by the Botswana Court of Appeal, the apex court in the Respondent State, are relevant to the issue of exhaustion of local remedies. The African Commission is, therefore, satisfied that the Communication has not contravened the provision of Article 56(5) of the African Charter. 109. According to Article 56(6) of the African Charter, Article 55 Communications will be considered if submitted to the African Commission within a reasonable time after the exhaustion of local remedies. While the African Charter is silent as to what amounts to a reasonable time, it is important to note here that, the issue of reasonable time is determined on a case to case bases taking into consideration all the relevant facts. The present Communication was submitted within four months following the decision of the Botswana Court of Appeal. The period of four months in the circumstances of this case is reasonable. The African 26

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