expected to have become aware of the Court, and 2016, the year the Application was filed, which is a period of three (3) years. 52. 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.”19 In view of this, the Court has taken into consideration circumstances such as incarceration and being on death row with the resultant limited movement and limited flow of information,20 being lay without the benefit of legal assistance21 and lack of awareness of the existence of the Court.22 Nevertheless, these circumstances must be proven. 53. In the present Application, the Court notes that the Applicant is not only incarcerated but has been on death row since his conviction and sentencing in 2005 with the resultant limitation in movement and flow of information, which, this Court has held in previous similar instances, could cause delays in filing applications.23 The Court finds that this situation negates the fourth ground of the Respondent State’s objection, namely, that the Applicant cannot claim that he was impeded in accessing the Court, as the issue is the timeliness thereof. The Court also notes that the Applicant is selfrepresented before this Court. 54. In view of these circumstances, the Court finds that the period of three (3) years that it took the Applicant to file the present Application is reasonable within the meaning of Article 56(6) of the Charter and Rule 50(2)(f) of the Rules. 19 Norbert Zongo and Others v. Burkina Faso (merits), supra, § 92. See also Thomas v. Tanzania (merits), supra, § 73. 20 Igola Iguna v. United Republic of Tanzania, ACtHPR, Application No. 020/2017, Judgment of 1 December 2022, §§ 37-38. 21 Thomas v. Tanzania (merits), supra, § 73; Jonas v. Tanzania (merits), supra, § 54; Amir Ramadhani v. United Republic of Tanzania (merits) (11 May 2018) 2 AfCLR 344, § 83. 22 Ramadhani v. Tanzania (merits), ibid, § 50; Jonas v. Tanzania (merits), ibid, § 54. 23 Thomas v. Tanzania (merits), supra, § 73; Jonas v. Tanzania (merits), supra, § 54; Ramadhani v. Tanzania (merits), supra, § 83; Iguna v. Tanzania, supra, § 39. 16

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