49. The Court further recalls, in line with its settled jurisprudence, that the local remedies to be exhausted must be available, effective and satisfactory. Moreover, the mere fact that a remedy exists does not satisfy the rule of exhaustion of remedies since an applicant is only required to exhaust a remedy insofar as it offers prospects of success.12 50. As it also emerges from the Court’s jurisprudence, the Applicant must not merely claim to have exhausted local remedies, but must have actually taken the steps provided for by domestic procedures in this regard.13 51. The Court notes that, in the present case, the local remedies exercised by the Applicant relate to four proceedings, namely those concerning: i) his dismissal; ii) the complaint against his lawyers; iii) the complaints against the Commissioner of the Cotonou Central Police, the Director General of National Police and the Minister of the Interior; and iv) the complaint relating to the attempted murder of his father. The Court will determine if the Application complies with the requirement of exhaustion of local remedies in relation to these proceedings. i. Proceedings in respect of dismissal 52. As regards the proceedings in respect of the Applicant’s dismissal, the Court notes that the Respondent State argues that the Applicant did not exhaust available remedies. The Court also notes that the Applicant himself does not deny knowing that, having appealed the Cotonou Court’s judgment before the Cotonou Court of Appeal, he failed to file his appeal submissions, which prevented the Court of Appeal from disposing of his case. 12 Beneficiaries of late Norbert Zongo, Abdoulaye Nikiema alias Ablasse, Ernest Zongo, Blaise Ilboudo and Mouvement Burkinabé des Droits de l’Homme et des Peuples v. Burkina Faso (merits) 28 March 2014) 1 AfCLR 219 § 68; Lohé Issa Konaté v. Burkina Faso (merits) 1 AfCLR 314, §§ 92 and 108; Sébastien Germain Marie Akoué Ajavon v. Republic of Benin (merits and reparations) (4 December 2020) 4 AfCLR 133, § 99. 13 Aminata Soumare v. Republic of Mali, ACtHPR, Application No. 038/2019, Judgment of 5 September 2023, § 45. 15

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