Seeking Remedies for Torture Victims: A Handbook on the Individual Complaints Procedures of the UN Tready Bodies for instance, the State party put forward that the author did not exhaust domestic remedies at his disposal because he failed to file an application to complain about the torture suffered. However, the author alleged that he had been held incommunicado during the several years he was imprisoned and, thus, he had not been able to file any complaint. In the absence of any plausible explanation by the State party, the HRC concluded that the remedy was de facto unavailable to the author.146 In Pratt and Morgan v. Jamaica, the HRC held that complainants are not required to exhaust domestic remedies which objectively have no prospect of success.147 A person’s subjective belief or presumption that a certain remedy is not effective does not absolve him or her of the requirement to exhaust all domestic remedies:148 the relevant remedy must be objectively ineffective. It can be difficult to establish that a remedy is objectively futile or unlikely to bring effective relief to the victim. For example, in P.M.P.K. v. Sweden the complainant alleged that her proposed expulsion from Sweden to Zaire would expose her to a real chance of torture in Zaire. Within eighteen months, she had already had two applications for asylum rejected. She asserted that a third application would be futile. While she had new evidence of her medical condition, she had no new evidence to counter the grounds upon which she had been previously unsuccessful, that is that she did not face a risk if returned to Zaire. Furthermore, only five percent of new applications were successful. Nonetheless, the CAT Committee found that it could not be conclusively stated that a new application would be ineffective or futile.149 A remedy will also be rendered ineffective if the complainant faces procedural obstacles attributable to the competent authorities. For instance, in S. Ali v. Tunisia the CAT found the case admissible because the lawyer was not allowed to register the complaint. The Committee asserted that under those circumstances, the author was confronted with an “insurmountable procedural impediment”.150 The same conclusion was drawn in Sahli v. Algeria, having considered the inaction of the prosecutor working in the courts of the district, which never replied to the complaints filed by the victim and their relatives challenging the arbitrary deprivation of liberty and the acts of torture that resulted in the death of the victim.151 Besides, the CAT Committee has asserted, within the framework of non-refoulement cases, that a remedy becomes “pointless” and, thus, there is no need to exhaust it, 146 HRC, Akwanga v. Cameroon, Comm. No. 1813/2008, para. 6.4. See also HRC, Traoré v. Côte d’Ivoire, Comm. No. 1759/2008, para. 6.5; HRC, Pavlyuchenkov v. Russian Federation, Comm. No. 1628/2007, para. 8.6. 147 HRC, Pratt and Morgan v. Jamaica, Comm. Nos. 210/1986, 225/1987, para. 12.3. 148 See HRC, R.T. v. France, Comm. No. 262/87, and Kaaber v. Iceland, Comm. No. 674/1995. 149 CAT Committee, P.M.P.K. v. Sweden, Comm. No. 30/1995, para. 7. 150 CAT Committee, S. Ali v. Tunisia, Comm. No. 291/2006, para. 12.3. 151 CAT Committee, Sahli v. Algeria, Comm. No. 341/2008, para. 8.5. 66