CDL-AD(2011)034 -8- would benefit from the competencies described above [the ones detailed by the ECRI General Policy Recommendation No. 7] would be equally adequate” (CDL-AD(2009)045, para. 38). Article 9 par 3 of the Law established that one of the Deputies will deal specially with discrimination issues. 37. Nevertheless, the Human Rights Protector of Montenegro, in order to become an effective national mechanism for the protection from discrimination, should have detailed and full powers to implement the anti-discrimination legislation. This would be the case only if he or she enjoyed all the competencies set forth by the General Recommendation No. 7 of the ECRI. Article 28 38. Paragraph 3 of the Article provides that for the Human Rights Protector to act on his or her own initiative the consent of the victim would be required. This Article refers to the general powers of the Protector and its possibility of different type of actions, such as investigative powers and the right to make human rights violations public. Therefore, in certain cases, in particular, where serious human rights violations have allegedly occurred or the rights of particularly vulnerable persons have allegedly been violated, the Protector should be entitled to act without seeking such consent in the general interest. 39. A different issue is the relationship between the Protector and the ordinary courts. As stated by the Venice Commission in former opinions, “in general, it would seem preferable to give the People’s Advocate the power to make general recommendations about the functioning of the court system, and exclude the power to intervene in individual cases (…)” (CDL-AD (2007)024, para. 19). Article 2 para. 2 is in line with this position, as it states that the Protector does not have authority over the work of the courts, except as determined by this Law. Article 32 40. This article has established a strict deadline of six months for filing a complaint within the Protector, but the inclusion of the second paragraph is welcome. As the complaints proceedings before the Human Rights Protector are not of a judicial nature, the possibility of being flexible when the importance of the case demands it is welcome. Article 46 41. This Article should have specified that the Rules of Procedure shall be approved by the Human Rights Protector. Article 47 42. The Annual Report of the Human Rights Protector plays an important role in facilitating parliamentary as well as public debate on the situation of human rights and freedoms in Montenegro. It is therefore to be welcome the inclusion in this Article of a reference concerning the submission of the Protector’s Annual Report to the Parliament. However, it could have been specified also that: 1) there should be a parliamentary debate on the Report; 2) the Report should contain a separate section on the activities of the Human Rights Protector as an NPM.