Notably, Alfred B. Cudjoe v Ghana did not supply reasons for limiting the local remedies to be exhausted to “courts of a judicial nature”. Article 56(5) of the Charter does not in itself also hint at the types of local remedies that ought to be exhausted. It is thus necessary to clarify that the essential characteristic of the remedy that ought to be exhausted for purposes of Article 56(5) of the Charter is its demonstrable effectiveness in redressing a particular violation. In this regard, the remedy must primarily conform to and operate in accordance with certain fundamental legal principles. It must operate in strict observance of the procedural guarantees of a fair hearing by a competent, independent and impartial organ.25 It must be based on enforceable law from which the relief it offers earns its mandatory or coercive force, as opposed to being merely discretionary.26 60. Cudjoe v Ghana27 is generally good authority and the Commission affirms it. However, the proposition for which it is authority must be understood in light of the standard constitutional model by which the competence to adjudicate complaints/disputes usually vests in national organs known as “courts of law” which in principle by their very design operate or ought to operate according to the standards enunciated at paragraph 59 above. This is the assumption underlying the proposition in Cudjoe v Ghana. It obviously is not the mere nomenclature by which the national organ is named that qualifies its mechanism as a remedy for purposes of Article 56(5) of the Charter. Indeed, even where the national organ is “a court” it is still possible that a Grievances Committee within the National Advisory Council; The National Commission on Human Rights; and Office of the Ombudsman, all rejected as remedies to be exhausted). 24 Communication 275/03 - Article 19 v Eritrea (2007) ACHPR para. 70 (writ of habeas corpus to the Minister of Justice rejected as a remedy to be pursued). 25 The Charter, Art. 7(1)(a) and (d) as read together with Art. 26; Communication 87/93 - The Constitutional Rights Project (in respect of Zamani Lekwot and six Others) v Nigeria (1995) ACHPR para. 8; Communication 147/83 - Lucía Arzuaga Gilboa v. Uruguay (1985) HRC para. 7.2 26 Communication 375/09 - Priscilla Njeri Echaria (represented by Federation of Women Lawyers, Kenya and International Center for the Protection of Human Rights) v. Kenya (Echaria v Kenya) (2011) ACHPR para. 53; Communications 48/90-50/91-52/91-89/93 - Amnesty International, Comité Loosli Bachelard, Lawyers' Committee for Human Rights, Association of Members of the Episcopal Conference of East Africa v Sudan (1999) ACHPR para. 31; Communication 313/05 Kenneth Good v Botswana (2010) ACHPR para. 88; Communication 87/93 - The Constitutional Rights Project (in respect of Zamani Lekwot and six Others) v Nigeria (1995) ACHPR para. 9; and Communication 231/99- Avocats Sans Frontières (on behalf of Gaëtan Bwampamye) v Burundi (2000) ACHPR para. 23; Communication 334/06 Egyptian Initiative for Personal Rights and Interights v. Egypt (2011) ACHPR para. 96; Velásquez-Rodríguez v. Honduras, n 14 above. 27 Above, n 9 17 | P a g e