30. The Complainants also argue that the Commission's jurisprudence does not require the exhaustion of local remedies in the context of serious and massive violations. 31. The Complainants refer to the case of Sudan Human Rights Organisation & Centre on Housing Rights and Evictions v. Sudan, in which the Commission found that "the scale and nature of the alleged abuses, the number of persons involved ipso facto make local remedies unavailable, ineffective and insufficient"." 32. The Complainants maintain that this Communication contains serious and massive violations. They furtherzargue' that, unlike in the Communication Socio-Economic Rights and Accountability Project (SERAP) v. Nigeria, which the Commission found inadmissible because a.: single incident, an oil pipeline explosion that caused 700 deaths and other permanent injuries, did not qualify as a case of serious and massive violations and/could have been the subject of a single tort lawsuit case under the Oil Pipelines Act (2004),8in the present Communication, each of the 40,000 daily maternal deaths and the estimated one million additional cases of maternal mo~bidity would be the subject of separate laws-uits 'address the violations that occurred in a single year.? The Complainantsfurther claim that they represent all the victims of a single year, in addition tp{Jhe cumulative total number of victims of past years, when maternal mort~lity and morbidity were even higher. to < 4:":'-':J~ . ,~i!:(., 'I.. ::{ :n. 33. The Complainants argue that dO?;testiclaw does not provide for any cause of action capable of grouEtng the. countless number of distinct violations into a manageable number of legal actions, and that tort law cannot provide sufficient redress that would bring about a structural change in the health care system. 34. The Complainants further contend that the present Communication is comparable to the Sudan Human Rights Organisation v. Sudan'» and Malawi Africa Association v. Mauritania't communications, in that the violations of maternal health care are serious and massive, occurring on a large scale and on a continuous basis. In addition, the Complainants allege that women in Nigeria have suffered serious and massive violations as a result of the conflict with Boko Haram in northern Nigeria. The Complainants state that hundreds of women were abducted, raped and gotten pregnant, and that even those who were released did not have access to adequate maternal health care.