iii. The fact that local remedies are not available to redress election grievances, or in the alternative, even though they may exist theoretically, they are insufficient. 85. On the first point, how do we quantify the “Ethiopian electorate” as referenced in this Communication? The Complainants seem to be referring to the whole country, and if that is the case, how do we establish whether the case falls within the purview of massive violations, which, according to the Commission’s jurisprudence, qualifies for a waiver of exhausting local remedies? 86. To answer these questions, it is necessary to examine the jurisprudence of the Commission that deals with the issue of massive violations that preclude victims from exhausting local remedies and compare them with the facts in the current Communication, and if the Communication doesn’t qualify, to set criteria for determining whether the violations are massive according to the facts of the case. 87. In Amnesty International and Others v. Sudan,30 which deals with allegations of extra-judicial killings, torture, arrests, and detention; the Commission distinguished between cases where the complaint deals with “violations against victims identified or named and those cases of serious and massive violations in which it may be impossible for the complainants to identify all the victims.” 88. Similarly, in Free Legal Assistance Group, Lawyers' Committee for Human Rights, Union Interafricaine des Droits de l'Homme, Les Témoins de Jehovah v DRC,31 which deals with allegations of arrests, detention, unfair trials, restriction on freedom of association, and freedom of the press, the Commission took the view that the condition to exhaust local remedies “cannot be applied literally, especially where it is impractical, or undesirable for all victims to seize domestic courts.” 89. In Sudan Human Rights Organisation & Centre on Housing Rights and Evictions (COHRE) v Sudan,32 which deals with large-scale killings, forced evictions, and forced displacement of populations, the destruction of public facilities and properties, and disruption of life through bombing by military fighter jets in densely populated areas, the Commission argued that in cases of serious and massive human rights 30 Communication Nos. 48/09,50/91,52/91,89/93- Amnesty International and Others v. Sudan, para 30 31 Communication Nos. 25/89-47/90-56/91-100/93 : Free Legal Assistance Group, Lawyers' Committee for Human Rights, Union Interafricaine des Droits de l'Homme, Les Témoins de Jehovah / DRC, para 37 32 Communication Nos. 279/03-296/05 : Sudan Human Rights Organisation & Centre on Housing Rights and Evictions (COHRE) / Sudan. ~ 15 ~ African Commission on Human and Peoples’ Rights 31 Bijilo Annex Layout, Kombo North District, West Coast Region, The Gambia, Phone: (220) 230 4361 Fax: (220) 441 05 04 Email: au-banjul@africa-union.org https:/achpr.au.int/