The Prohibition of Torture and Ill-treatment in the African Human Rights System: A HANDBOOK FOR VICTIMS AND THEIR ADVOCATES This is borne out of the fact that the Charter makes use of the word “exclusively”. There is no doubt that the media remains the most important, if not the only source of information… The issue therefore should not be whether the information was gotten from the media, but whether the information is correct. Effectively, the Commission in this case recognised the rationale underlying Article 56(4) but circumscribed its effect. This is particularly relevant to torture cases. By its very nature, torture is often difficult to prove. Physical injuries may in many cases not be visible, and even visible injuries may be explained in more than one way. Media reports may be instrumental in corroborating torture or its widespread use. The Commission has upheld this position in subsequent cases.360 f. Local Remedies Must First Be Exhausted361 The Charter requires authors of communications to exhaust local remedies before resorting to the procedures of the African Commission.362 The mechanisms of the African Commission are not processes of first instance. They complement and reinforce national protection mechanisms. This principle of complementarity is the basis for the rule on exhaustion of domestic remedies, which is the cornerstone of the procedure for remedies under the African Charter.363 In determining these factors, the Commission has emphasised that the purpose of the requirement to fulfil domestic remedies is to allow a State the opportunity to address such allegations internally before they are brought to an international forum for consideration.364 However, this requirement does not mean that complainants are required to exhaust any local remedy which is found to be, as a practical matter, unavailable or ineffective.365 The Commission has recognised that this provision implies and assumes the availability, adequacy and effectiveness of domestic adjudication procedures.366 Only remedies of a ‘judicial’ nature need to be exhausted. For this reason, non-judicial 360 See, e.g., ACHPR, Zimbabwe Human Rights NGO Forum v. Zimbabwe, Comm. No. 245/02, para. 43. 361 African Charter, supra note 9, art. 56(5). 362 Ibid. This is the most controversial and far-reaching of the admissibility requirements in the African Charter. See N. J. Udombana, “So Far, so Fair: The Local Remedies Rule in the Jurisprudence of the African Commission on Human and Peoples’ Rights”, 97 American Journal of International Law 1 (2003). 363 African Charter, supra note 9, art. 56(6). 364 See, for example: ACHPR, Sir Dawda K. Jawara v. The Gambia, Comm. Nos. 147/95 & 149/96, para. 31; Rencontre Africaine pour la Defense des Droits de l’Homme (RADDHO) v. Zambia, Comm. No. 71/92, 71/92, 20th Ordinary Session (31 October 1997), reprinted in 6 International Human Rights Reports 825; SocioEconomic Rights and Accountability Project (SERAP) v. Nigeria, Comm. No. 338/07, 48th Ordinary Session (28 November 2010), para. 58. 365 Ibid. 366 ACHPR, Sir Dawda K. Jawara v. The Gambia, Comm. Nos. 147/95 & 149/96, para. 31; Constitutional Rights Project (in respect of Zamani Lekwot and 6 Others) v. Nigeria, Comm. No. 87/93, para. 6. 88