p.CHP1f t~ r16~!j,E~ Humao RighW °"' Human and Peoples' Rights Collect,ve Responsibility v. the Republic of Kenya13 that "Where an Applicant proves that a matter has passed through the appropriate domestic judicial procedures, the requirement of exhaustion of local remedies is presumed to be satisfied, even if the same Applicant before this Court has not brought the matter before the domestic courts". 81. It is clear that this is a matter that is sufficiently dealt with by the national judicial bodies, as opposed to measures focusing solely on whether or not the complainant himself has had recourse to all local remedies. In this regard, the Commission considers that the conditions of Article 56(5) have been met. 82.Apart from efforts to exhaust domestic remedies without success, the nature of communication seems to suggest that domestic remedies are insufficient, if not outright non-existent. This may be due to the difficulty, as illustrated by the various cases that members of affected communities have repeatedly submitted to the courts of the Respondent State, that complainants and communities in similar situations face in finding appropriate legal frameworks that effectively recognize and faci litate the legal enforcement of collective land ownership. Submission within a reasonable time (Article 56(6)) 83. Article 56(6) of the African Charter requires that Communications be "lodged within a reasonable time from the exhaustion of domestic remedies or from the date on which the matter was submitted to the Commission." 84.The Complainants allege and the Commission has clearly demonstrated that the effort to exhaust local resources was quite evident. However, all cases submitted to the Court of Appeal, the High Court and the Constitutional Court were dismissed. 85. The last cas was filed with the High Court in October 2019, and the Commission received the complair-it in July 2021 , some twenty-one months after the case was filed . The issue at hand here would be whether or not these twenty-one months can be regarded as a reasonable period for referring a case to the Commission. 86. It has been well established, both by international human rights bodies such as the Inter-American Court of Human Rights and the African Commission itself, that the reasonable period during which a case must be submitted to the Commis§j·~ ~~::s... final decision by the national judicial body is six months. ,p~~~;E~~;~;-\'o'°··. ~ oI"• ,;; «"o 1 (1' ~ u 13African Commission on Human and Peoples' Rights v. Republic of Ke nya !!!J.r~1fric,111lii.11rJ>.Lc!l\!Li!!.l!&!!JJ:l!!L!W'i ,n -co irl 2 uJ :c ti i1 0 \ .__. "l•~,c,o.lN EET .- - o;;: ., '