registry on 28 July 2016. In total, therefore, the Applicants took ten (10) months and twelve (12) days before filing the Application. It is this period that the Court must assess for reasonableness under Article 56(6) of the Charter. 43. The Court recalls its jurisprudence that: “… the reasonableness of the timeframe for seizure depends on the specific circumstances of the case and should be determined on a case-by-case basis.”9 Following this approach, the Court has taken into consideration circumstances such as incarceration and being on death row with the resultant limited movement and limited flow of information10 in determining the reasonableness of time. In all instances, however, the Applicant bears the burden of proving how his/her personal circumstances affected the time within which the Application was filed. 44. Regarding the Respondent State’s submission that a period of six (6) months is accepted as reasonable time for filing applications in international human rights law, the Court reiterates the open-ended nature of Article 56(6) of the Charter, which is replicated in Rule 50(2)(f) of the Rules. The result is that no pre-fixed time frame applies for determining reasonableness of time for filing an Application before the Court. The Court thus rejects, as being without legal basis, the Respondent State’s submission that a period of six (6) months should be applied in determining reasonableness of time for filing Applications. 45. In considering the Applicants’ situation as incarcerated individuals who had to rely on prison authorities to access their court records, and also considering the time at stake herein, ten (10) months and twelve (12) days, the Court holds that the time it took the Applicants to file their Application is 9 Zongo and Others v. Burkina Faso (merits), supra, § 92. See also Thomas v. Tanzania (merits) supra, § 73. 10 Igola Iguna v. United Republic of Tanzania, ACtHPR, Application No. 020/2017, Judgment of 1 December 2022 (merits and reparations), §§ 37-38. 13

Select target paragraph3