- 45 126. Ukraine argues that local remedies must be exhausted only when a State brings a claim on behalf of one or more of its nationals. According to the Applicant, the rule of exhaustion of local remedies has no application in the present case since Ukraine’s claims relate to an alleged pattern of conduct of the Russian Federation, and Ukraine is invoking the rights it holds as a State under CERD. Ukraine contends that the Russian Federation’s objection is not persuasive because Ukraine did not bring the present case to vindicate individual rights. On the contrary, Ukraine seeks an end to the Russian Federation’s alleged “systematic campaign of racial discrimination” in violation of CERD. 127. Ukraine states that both the structure of CERD and the plain language of its provisions contradict the Russian Federation’s argument. Ukraine emphasizes that references to the rule of exhaustion of local remedies are contained in Part II of CERD concerning the procedure before the CERD Committee, whereas Article 22 is located in Part III of the Convention, which makes no reference to the rule of exhaustion of local remedies. On this basis, Ukraine infers that the rule of exhaustion of local remedies applies only in the context of the CERD Committee procedure. Ukraine further submits that, in any event, Article 11, paragraph 3, and Article 14, paragraph 7 (a), of CERD have no relevance in the present case: first, as a sovereign State, Ukraine cannot be expected to submit itself to the domestic courts of another sovereign State; secondly, bringing a dispute before the courts of the Russian Federation would be futile, as Ukraine could not expect a fair hearing of its claims. 128. Ukraine states that the cases heard by human rights courts on which the Russian Federation relies all concern claims by individuals or non-governmental organizations acting on their behalf. Ukraine relies on the jurisprudence of the European Court of Human Rights and of the African Commission on Human and Peoples’ Rights, which, in its view, supports its position that the rule of exhaustion of local remedies does not apply in the present case. In particular, Ukraine refers to a decision in which the European Court of Human Rights held that the rule of exhaustion of local remedies “does not apply where the applicant State complains of a practice as such . . . but does not ask the Court to give a decision on each of the cases put forward as proof or illustrations of that practice” (Georgia v. Russia (II), Application No. 38263/08, Decision on Admissibility of 13 December 2011, para. 85). Ukraine concludes that the rule of exhaustion of local remedies does not apply in the present case and that its Application is consequently admissible. * * 129. The Court recalls that local remedies must be previously exhausted as a matter of customary international law in cases in which a State brings a claim on behalf of one or more of its nationals (Interhandel (Switzerland v. United States of America), Preliminary Objections, Judgment, I.C.J. Reports 1959, p. 27; Elettronica Sicula S.p.A. (ELSI) (United States of America v. Italy), Judgment, I.C.J. Reports 1989, p. 42, para. 50; Ahmadou Sadio Diallo (Republic of