l'CHP,9 r~ r16~!j,iEfi Human and Peoples' Rights Human Rights our Collective Respons1b1ilty Committee for Human Rights, Jehovah's Witnesses, the Inter-African Union for Human Rights v. Zaire11. 70. In the above-mentioned case, the Commission clearly stated that in order to refer a case to the institution about alleged human rights violations, the Complainants must effectively exhaust local remedies. However, without going into detail on the merits of the case, the Commission declared the Complaint admissible due to evidence of massive human rights violations, which constitutes an exceptional approach to the normal application of the principle of exhaustion of domestic remedies. 71 . The Commission's aim is to assert its position, in harmony with international law, as a court of last resort, rather than to be seized as a court of first instance, unless circumstances so require, and under exceptional and specified conditions. From this point of view, the Commission stated in the case of Mr Dawda K. Jawara12 that local resources should be exhausted if they are available, effective and sufficient. The implication of this is that, unless it is clearly established with convincing evidence demonstrating the unavailability, inefficiency or insufficiency of local resources, the Commission cannot relieve claimants of the obligation to demonstrate exhaustion of domestic remedies. 72. The Commission observes that since its jurisdiction is complementary to national mechanisms and acts when such mechanisms are unable or refuse to provide remedies, where the Commission replaces itself with national mechanisms (the main venue for obtaining remedies) by admitting communications without exhaustion of domestic remedies, it needs to be based on a very robust presentation, otherwise the Commission would be accused of acting as a court of first instance and thus of substituting itself for national judicial proceedings. 73. Therefore, before determining whether a complainant has effectively exhausted domestic remedies, it is essential to analyse the efforts made by complainants to exhaust those remedies by referring the case to national judicial proceedings. 74. In this case, the complainants allege that the Respondent State dealt with th extensively and sufficiently. Several members of the l<edong appealed to all necessary judicial instances, without any form of o 11 Communicotion 25/89, 4i / 90, 56/91, IOll/93 World Organization Ag,1fost Tortu<\?, the Lawyers'Commillec for Human Rights Union for Human Rights v. Zaire hllp:t/hrlil>r,1rv.umn.c,H1 /~frica/lomcases/Com11125-89.1>dl 12Communicdtion 147/95-149/96: Mr. Dowda K. Jawara v. Tiie Gambia fih•:///C:/t:ser;/rnJ11iod/Dnwnlo,uls/,1,hpr27 '147.9" 9 14