137 and 131 respectively of the Constitution of Ghana. In this regard, the [African] Commission draws the attention of the parties to the similar case of communication 135/94 Kenya Human Rights Commission / Kenya, where it had held that "...the facts supplied by the Complainants themselves stated that the communication was pending before the Courts of Kenya,... [and] that the Complainants had therefore not exhausted all available local remedies". 36. Therefore, although the communication presents a prima facie case of a series of violations of the African Charter, a close look at the file and the submissions indicate that the complainant is yet to exhaust all the local remedies available to him. 37. With regard to Article 56(6) of the [African] Charter which provides that communications shall be considered if "... they are submitted within a reasonable period of time from the time local remedies are exhausted, or from the date the Commission is seized of the matter", the [African] Commission holds that this is quite related to the principle of the exhaustion of local remedies in accordance with Article 56(5). This means that the Commission estimates the timeliness of a communication from the date that the last available local remedy is exhausted by the Complainant. In the case of unavailability or prolongation of local remedies, it will be from the date of the Complainant's notice thereof. 38. Unlike its Inter-American3 contemporary, the Commission does not specify a time-period within which communications must be submitted. However, it advised on the early submission of communications in the case of communication 97/93 John K. Modise/Botswana. 39. However, having found that the Complainant has not exhausted local remedies the [African] Commission concurs with the Respondent State's argument that the Complainant had acted impetuously in bringing this communication. This is because the matter has not been concluded, for which reason time has not begun to run such as to afford the Complainant the opportunity to bring this complaint. Holding For these reasons, the African Commission, Declares the communication inadmissible for non-exhaustion of local remedies. Done at the 40th Ordinary Session held from in Banjul, The Gambia, 15th to 29th November 2006. 1 Ghana ratified the African Charter on 24th January 1989, and is thus a State Party. 2 ACHPR /Res. 21(XIX) 96. 3 Article 32 × Article 32. Publication of Judgments and Other Decisions 1. The Court shall make public: a. its judgments, orders, opinions, and other decisions, including separate opinions, dissenting or concurring, whenever they fulfill the requirements set forth in Article 65(2) of these Rules; b. documents from the case file, except those considered unsuitable for publication; c. the conduct of the hearings, except private hearings, through the appropriate means; d. any other document that the Court considers suitable for publication. 2. Judgments shall be published in the working languages used in each case. All other documents shall be published in their original language. 3. Documents submitted to the Secretariat of the Court that relate to cases already adjudicated shall be made accessible to the public, unless the Court decides otherwise. of the Rules of Procedure of the Inter-American Commission. 5