26 Thus, in Communication Nos 147/95, 147/96 Sir Dawda K. Jawara v The Gambia, Thirteenth Annual Activity Report (1999-2000) at paragraph 31, the African Commission stated that: “Three major criteria could be deduced in determining [the exhaustion] rule, namely: the remedy must be available, effective and sufficient.” In Communication No 221/98 Alfred B. Cudjoe v Ghana, Twelfth Annual Activity Report (1998-1999) at paragraph 13, the Commission had earlier stated that: “[T]he internal remedy to which Article 56(5) [of the Charter] refers entails a remedy sought from courts of a judicial nature.” In the Case of Velásquez-Rodríguez v. Honduras, Judgment of July 29 1988, Series C No 4 paragraph 64, the Inter-American Court of Human Rights stated that: “Adequate domestic remedies are those which are suitable to address an infringement of a legal right. A number of remedies exist in the legal system of every country, but not all are applicable in every circumstance. If a remedy is not adequate in a specific date, it obviously need not be exhausted.” In a similar vein, the European Court of Human Rights in Akdivar and Others v Turkey Application no. 21893/93 Judgment of 16 September 1996 Reports of Judgments and Decisions 1996 IV page 1210 paragraph 66 stated that: