- Article 3 on the right to non-discrimination and Article 13 on the rights of children with disabilities - Article 5 on the right to life, survival, and development - Article 11 on the right to education - Article 16 on freedom from torture and inhumane treatment III. Complainants’ Submission on admissibility 13. The Complainants submit that the Committee is seized with jurisdiction to consider the present Communication pursuant to Article 44 of the Charter and Section II(1) of the Communications Guidelines. They submit that the Respondent State has ratified the Charter and that the allegations concern violations of the provisions thereof. Moreover, the Complainants argue that they have standing before the Committee in line with Section I(1) of the Communications Guidelines, as they are registered in a Member State of the African Union. Moreover, it is provided that, two of the Complainants, the Institute for Human Rights and Development in Africa and the Centre for Human Rights, have observer status before the Committee. The Complainants also submit that obtaining the consent of the victims was impracticable in light of the alleged systemic nature of the violations, relying on the Committee’s jurisprudence in the Nubian Children case. 14. Regarding the Conditions of admissibility, the Complainants submit that they have fulfilled all the conditions of admissibility listed under Section IX(1) of the Communications Guidelines. In particular, the Complainants submit detailed arguments on the exhaustion of local remedies and emphasizing that the requirement is not without exceptions. They submit that the Respondent State has been duly notified about the ongoing violations, which constitutes one of the underlying rationales for exhaustion of local remedies requirement. The Complainants substantiate their arguments based on the jurisprudence of the Committee in the Michelot Hansungule and others v Uganda case as well as the jurisprudence of the African Commission on Human and Peoples’ Rights (ACHPR) in the Communication of SERAC v Nigeria. The Complainants argue that the alleged violations are massive violations and affect a large number of children, thereby warranting exemption of the requirements of local remedies as recognised in the Committee’s jurisprudence in the Talibes Case. The Complainants further submit that the available local remedies are contingent upon the action of the Respondent State, which has the primary duty to investigate and prosecute perpetrators and that it is not up to the victims to undertake investigation. In this regard, the Complainants refer to the jurisprudence of the ACHPR in the Zimbabwe Human Rights NGO Forum v Zimbabwe case where the ACHPR decided that in cases that require criminal action against perpetrators, victims cannot be required to exhaust local remedies.1 Furthermore, the Complainants submit that the 1 African Commission on Human and Peoples’ Rights (ACHPR), Communication No. 245/2002, Zimbabwe Human Rights NGO Forum V Zimbabwe (2006) AHRLR 128 (ACHPR 2006) para 70. 4