46. The Court observes that neither the Charter nor the Rules specify the exact time within which applications must be filed, after exhaustion of local remedies. Article 56(6) of the Charter and Rule 50(2)(f) of the Rules merely provide that applications must be filed “… within reasonable time from the date local remedies were exhausted or from the date set by the Court as being the commencement of the time limit within which it shall be seized with the matter”. 47. The Court has previously held “… that the reasonableness of the time frame for seizure depends on the specific circumstances of the case and should be determined on a case-by-case basis”.12 Some of the circumstances that the Court has taken into consideration include: duration of time of the litigation procedure at the domestic courts;13 imprisonment, indigence, illiteracy and the use of extra-ordinary remedies.14 Nevertheless, these circumstances must be proven. As the Court has previously pointed out, even for lay, incarcerated or indigent litigants there is a duty to demonstrate how their personal situation prevented them from filing their applications within a reasonable time.15 48. The Court notes from the record that the Applicant exhausted local remedies on 28 November 2011, when the Court of Appeal dismissed his appeal for lack of merit. He avers without producing any evidence that he filed a “Notice of Motion for Review” of the Court of Appeal’s decision to the same court two (2) months later. The Applicant then filed his Application before the Court on 4 January 2016. The Court, therefore, has to assess whether the period running from 28 November 2011 to 4 January 2016, when the Applicant seized this Court, that is, four (4) years, one (1) month 12 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. United Republic of Tanzania (merits) (20 November 2015) 1 AfCLR 465, § 73. 13 Ernest Karatta, Walafried Millinga, Ahmed Kabunga and 1744 Others v. United Republic of Tanzania, ACtHPR, Application No. 002/2017, Judgment of 30 September 2021 (merits and reparations), § 65. 14 Guehi v. Tanzania, supra, § 56; Werema Wangoko Werema & Another 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. 15 Hamisi Mashishanga v. United Republic of Tanzania, ACtHPR, Application No. 024/2017, Ruling of 1 December 2022 (jurisdiction and admissibility), § 67. 14