24 ORLOVSKAYA ISKRA v. RUSSIA JUDGMENT whether any of these proceedings should be accepted for the purpose of applying the six-month rule contained in Article 35 § 1 of the Convention. 63. The Court reiterates that the primary purpose of the six-month time-limit provided for by Article 35 § 1 of the Convention is to maintain legal certainty by ensuring that cases raising issues under the Convention are examined within a reasonable time, and to prevent the authorities and other persons concerned from being kept in a state of uncertainty for a long period of time (see Sabri Güneş v. Turkey [GC], no. 27396/06, § 39, 29 June 2012). This time-limit also affords the prospective applicant time to consider whether to lodge an application and, if so, to decide on the specific complaints and arguments to be raised, and facilitates the establishment of the facts in a case, since with the passage of time any fair examination of the issues raised is rendered problematic (ibid.). The Court may only deal with the matter within a period of six months following the “final decision” at domestic level. Such a “final decision” is taken following exhaustion of the effective and available domestic remedies, namely those which were accessible, capable of providing redress in respect of the applicant’s complaints, and offered reasonable prospects of success (see Akdivar and Others v. Turkey, judgment of 16 September 1996, § 68, Reports of Judgments and Decisions 1996-IV). 64. Various defects in the domestic procedure may indicate that decisions taken in that procedure would not be taken into consideration for the purpose of applying the six-month rule. For instance, remedies which have no time-limits, thus creating uncertainty and rendering nugatory the six-month rule contained in Article 35 § 1 of the Convention, are not effective remedies within the meaning of Article 35 § 1 (see Galstyan v. Armenia, no. 26986/03, § 39, 15 November 2007, and Berdzenishvili v. Russia (dec.), no. 31697/03, ECHR 2004-II (extracts)). 65. It is noted that the applicant organisation challenged the court decisions in the CAO case before courts at higher levels of jurisdiction. 66. According to the Court’s established case-law, an application for supervisory review in civil proceedings did not constitute a remedy under Article 35 § 1 of the Convention (see Tumilovich v. Russia (dec.), no. 47033/99, 22 June 1999, and Denisov v. Russia, (dec.), no. 33408/03, 6 May 2004). In the Martynets case ((dec.), no. 29612/09, 12 December 2008), where the Court examined the supervisory-review procedure which was in force between January 2008 and January 2012, it found that this procedure continued to leave binding judicial decisions open to indefinite challenge, thus generating unacceptable uncertainties as to the final point in the domestic litigation. The Court reached this conclusion notwithstanding the tangible changes brought to this procedure, such as the reduction of the time-limit for lodging a supervisory review application from one year to six months, the introduction of an obligation of prior exhaustion of ordinary avenues of appeal, and the abolition of the essentially unfettered