40. In view of the foregoing, the Court finds that the Applicant exhausted local
remedies and thus the Application satisfies the requirement of Rule 50(2)(e)
of the Rules.
41. As regards the requirement to file an application within a reasonable time
after exhaustion of local remedies, the Court recalls that assessment of
reasonable time for referral depends on the particular circumstances of
each case.9 It has held, in particular, that where the period in question is
relatively short, the period is regarded as manifestly reasonable.10
42. In this regard, the Court recalls that local remedies were exhausted on 25
August 2020, the date the Abidjan CFI rendered its decision. This date is
therefore the starting point to determine reasonable time for referral.
43. The Court notes that between 25 August 2020 and 7 September 2020 when
the present Application was filed,13 days elapsed. The Court finds that the
time taken to seize the Court is manifestly reasonable within the meaning of
Article 56(6) of the Charter. The Application therefore meets the
admissibility requirement under Rule 50(f) of the Rules.
44. Finally, as regards the admissibility requirement under Article 50(g) of the
Rules, the Court finds that there is nothing in the record to indicate that the
application concerns a matter that has already been settled by the Parties
in accordance with the principles of the Charter of the United Nations, the
Constitutive Act, the provisions of the Charter or any legal instrument of the
African Union. Accordingly, the Court finds that the Application complies
with Article 56(7) of the Charter and Rule 50(2)(g) of the Rules.
9 Beneficiaries of the late Norbert Zongo and Others v. Burkina Faso, (merits) (24 June 2014) 1 AfCLR
219, § 92; Thomas v. Tanzania (merits), supra, § 73; Boniface Aristedes v. United Republic of Tanzania,
AfCHPR, Application No. 025/2018, Judgment of 5 February 2025 (merits and reparations), § 49.
10 Niyonzima Augustine v. United Republic of Tanzania, AfCHPR, Application No. 058/2016, Judgment
of 5 September 2023 (merits and reparations), § 55; Ligue ivoirienne des droits de l’homme (LIDHO)
and Others v. Republic of Côte d’Ivoire, AfCHPR, Application No. 041/2016, Judgment of 5 September
2023 (merits and reparations), §105, Kanté and Others v. Republic of Mali (Admissibility) (25 June 2021)
5 AfCLR 222, § 36, Komi Koutché v. Republic of Benin (jurisdiction and admissibility), (26 September
2021) 5 AfCLR 231, § 36.
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