Resettlement and others,3 where he submits that no attempt has been made to act upon orders of the High Court against the Commissioner of Police. 31. The Complainant states further that, Zimbabwe Lawyers for Human Rights has documented at least 12 cases since 2000 in which the State has ignored court rulings. He submits that some of the most egregious examples of non-enforcement of judicial rulings include the case of Journalists Mark Chavunduka and Ray Choto who were abducted and tortured by the army.4 32. The Complainant states that a Supreme Court-ordered police investigation in 2000 on the above case, but failed to proceed. Hence, it is the Complainant‟s submission that the Victim has no prospect of success in pursuing local remedies in Zimbabwe. It is also the Complainant‟s contention that the uncertainty of the factual existence of a remedy for the Victim is indubitable, and therefore lacks the requisite effectiveness. 33. Concerning Article 56(6) of the African Charter, the Complainant submits that the Communication complies with the requirement under this Article. He substantiates this argument by stating that where a Complainant is unable to obtain redress locally, and is not required to exhaust local remedies as in the instant case, reasonable time could be determined by having regard to the date of violation and date of submission as practiced in the Inter-American Human Rights System. The Complainant states that it has only been less than four months since the violations occurred, 3 Supreme Court Ruling, (132-2000). 4 Justice system eroded by state non-compliance available at www.allaafrica.com. 8

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