73. In addition, the Complainant responds to the assertions of the State that the law criminalises ill-treatment during detention and that it is easy for the immunities to be lifted where there is an accusation of a violation of human rights. The Complainant notes that such immunities apply to police and NISS respectively and thus the dispute in fact between which was responsible for the arrest does not affect this argument. The Complainant refers to previous jurisprudence of the Commission which found that these immunities are an impediment to initiating action against the NISS or police and that they render remedies ineffective and inadequate. They further submit that the impunity provisions sustain a culture of systemic impunity, rendering al possible remedies discretionary and extraordinary. 74. In relation to the argument of the ease with which immunities can be lifted, the Complainant states that this is irrelevant to the question of whether there were remedies, and refers to jurisprudence in which the Commission had decided that "when a remedy is discretionary, extraordinary and of a non-judicial nature, the Complainants are not require to pursue it as part of the requirement of exhaustion of local remedies"'15 and "it would be improper to insist on the Complainant seeking remedies from a source which does not operate impartially and has no obligation to decide according to legal principles" .16 They further reiterate the decision of the Commission in a previous case that it is implausible to think that the heads of the police and NISS would lift the immunities, and also noting that there is no procedure in legislation for lifting these immunities, thus making them discretionary. The Complainant thus submits that the Commission should find Article 56(5) has been complied with. 75. In relation to the arguments of the State on Article 56(6) that the Complainant had not shown manifested reasonable justification for the delay in filing the Complaint and that eleven months is not a reasonable time, the Complainant states that the State did not respond with adequate specificity as to the factors which determine whether there was a reasonable period, thus failing to demonstrate that these factors did not amount to a reasonable justification for the lapse of time.