Nixon Nyikadzino v Zimbabwe Relying on case law ... the Commission finds that the Complainant is unable to pursue any domestic remedy following his flight to the Republic of Congo for fear of his life ... The Commission therefore declared the communication admissible based on the principle of constructive exhaustion of local remedies. 30. Similarly the Complainant avers that the Victim fled Zimbabwe in fear for his life after being tortured by the Zimbabwean military because of his affiliation with an organization lobbying for constitutional reform. The Victim according to the Complainant is now in South Africa, and remains fearful of further attacks should he return to Zimbabwe, particularly in light of the widely-reported and continuing attacks against opposition leaders and activists by members of the uniformed forces who do so with no punitive sanctions from the Zimbabwe Government. 31. In light of the above the Complainant submits that the Victim was forced to flee from Zimbabwe and remains outside the country due to a generalized fear for his life, and consistent with the Commission's jurisprudence above, local remedies are unavailable and constructively exhausted. 32. As stated above, the Complainant argues, a remedy is effective only when it offers a prospect of success.10 When remedies are formally available but courts are not independent or impartial, the remedies will be deemed ineffective.n 33. The Complainant contends that because the Zimbabwean judiciary is no longer fully independent and is subject to political pressure, and because court orders in Zimbabwe are regularly ignored by Zimbabwean authorities, particularly in cases that involve politically-motivated violence, local remedies offer the Victim no reasonable prospect of success and are ineffective. 10 11 Jawara v The Gambia para. 32. Communication 60/91 - Constitutional Rights Project v Nigeria (1994) ACHPR para. 10. 8JPage 11 th Extraordinary Session of the ACHPR