Pre-Trial Detention

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Background

Pre-trial detention is when a person is held by the State for an offense committed against the laws of the State prior to trial. Pre-trial detention remains a problem around the world despite international standards and domestic laws cautioning against pre-trial detention. By some estimates, there as many as three million people held in pre-trial detention at any given time.[1] Often, prisoners are held for years without any hope or opportunity for trial. In Nigeria the average period of pre-trial detention while waiting trial is 3.7 years. [2] In countries with the most broken criminal justice systems, cases may take long periods to resolve. As a result, the pre-trial detention population often swells. In Liberia, for instance, almost 97 percent of all those in prison are pre-trial detainees.[3]

Although there are multiple issues arising from pre-trial detention- from inhumane conditions to the length of detention- this narrative will focus primarily on the determination and length of detention in the traditional criminal justice setting.

Some countries may also permit administrative detention of suspects that falls outside the scope of this particular article.

International Standards: Basic Tenets Protecting Against Pre-trial Detention

An individual's protection against pre-trial detention is grounded in fundamental rights of liberty and security.

Universal Declaration of Human Rights

Under the Universal Declaration of Human Rights, every person charged with a crime has the right to a presumption of innocence until proven guilty. Therefore, pretrial detention is applicable only when:

  1. there are reasonable grounds to believe the alleged perpetrator committed a crime,
  2. there is a danger the alleged offender will flee or
  3. there is a danger that the course of justice will be seriously obstructed if the alleged offender is freed.[4]

United Nations Standard Minimum Rules for Non-Custodial Measures

Additionally, the United Nations Standard Minimum Rules for Non-Custodial Measures stipulates that governments should use pretrial detention as a last resort in criminal proceedings, and only for the protection of society and the victim. Furthermore, governments should pursue alternatives as early as possible. Pretrial Detention should last for only as long as is necessary and should be administered humanely. The offender has the right to appeal when detained pretrial.[5]

International Covenant on Civil and Political Rights

Under Article 9(3): "It shall not be the general rule that a person awaiting trial shall be detained in custody, but release may be subject to guarantees to appear for trial, at any other stage of the judicial proceedings, and, should occasion arise, for execution of the judgment."[6]

The above provision, along with the Universal Declaration of Human Rights has been interpreted by the UN Human Rights Committee[7] to mean that:

  • detention prior to trial should only be used where lawful, reasonable and necessary.

The necessity requirement has been interpreted very narrowly by the Committee. Detention may be necessary:

  • to prevent flight,
  • to prevent interference with evidence
  • to prevent the recurrence of crime, or
  • where the person concerned constitutes a clear and serious threat to society which cannot be contained in any other manner.

The severity of a crime or the need for continued investigation are not enough to justify pre-trial detention alone.[8]

In addition, any country whose domestic system does not provide an alternative to confinement other than supervised release, which is only granted under specific circumstances without any provisions for bail, is not in conformance with Article 9(3) of the ICCPR.

Length of Pre-Trial Detention

Article 9(3) of the ICCPR guarantees a right to trial within a reasonable time, or alternatively the right to release.[9] However, "reasonable" is not strictly defined. The Human Rights Committee has interpreted the provision to mean that every individual has a right to a final judgment without undue delay.[10] The Committee has interpreted the provision in this manner to guard against lengthy delays following the commencement of a trial. This provision should protect against long continuances or delays between the presentation of evidence and judgment.[11]

Additionally, it is the State's responsibility to ensure that individuals are not detained prior to trial for an unreasonable amount of time. The burden is not on the accused to assert the right to a prompt trial, but rather on the State.[12] What constitutes a reasonable amount of time is assessed within the context of each individual case.[13]

In one case, the Committee implied that Yemen's domestic legislation, which included a six-month limit on pre-trial detention, was too long of a time period to be compatible with Article 9(3) of the ICCPR.[14]

Furthermore, the Committee has provided guidelines for States regarding pre-trial detention.[15] The Human Rights Committee has urged States to establish a maximum period for pre-trial detention. If an individual is detained for a period exceeding the maximum, the individual should be entitled to release. In establishing a maximum pre-trial detention period, States should evaluate the maximum incarceration period for the alleged crime and determine a proportionate length.[16]

Judicial Review of Confinement

The right to challenge detention before a judicial authority with the power to order release is guaranteed to any individual deprived of liberty, including pre-trial detainees.[17] This right is in addition to the right to be presented in front of a judicial authority following arrest, and applies whenever an individual is detained. In domestic legislation, this right is often referred to as the right to habeas corpus or amparo proceedings. For effective implementation, the detainee must have notice of why he or she is being held, and have access to legal counsel.[18]

Article 8 of the Universal Declaration of Human Rights establishes that "everyone has the right to an effective remedy by the competent national tribunals for acts violating the fundamental right granted him by the constitution or by law."[19]

In addition, the ICCPR states in Article 9(4):

  1. A detained person or his counsel shall be entitled at any time to take proceedings according to domestic law before a judicial or other authority to challenge the lawfulness of his detention in order to obtain his release without delay, if it is unlawful.
  2. The proceedings shall be simple and expeditious and at no cost for detained persons without adequate means. The detaining authority shall produce without unreasonable delay the detained person before the reviewing authority.[20]

The Human Rights Committee has interpreted Article 9(4) to mean that an authority cannot become "a court" simply because it adheres to established legal procedures. The purpose of Article 9(4) is to ensure a court reviews detention, not merely any authority governed by law. A court must be objective and independent.[21]

Article 9(4) applies to all detention, including detention ordered by an administrative body or authority.[22]

Case Studies

Azerbaijan

In Azerbaijan, pre-trial detention is the preferred means of dealing with accused people charged with crimes. Though alternatives such as home arrest, bail, and police supervision exist, pre-trial detention is overwhelmingly preferred, especially for those charged with grave crimes.[23]

Requirements of "lawful, reasonable and necessary:" interpretation and impact

Though the legal codes reflect the terms mandated by the UN, in practice "reasonable" and "necessary" are ignored by Azerbaijan's judicial system.[24]

Discrepancy between country's laws/codes, international standards and practical implementation

There is not much discrepancy between Azerbaijan's domestic codes and international standards. However, there is a serious difference in the practical implementation of the laws.[25]

Detainment

Courts have determined that less grave crimes require detainment of no more than three months, whereas grave crimes committed by individuals presenting a public danger require a longer detention period of up to twelve months.[26]

Though bail exists as a remedy to pre-trial detention, it is extremely rare. Often, a court will determine release terms at the same time as bail, therefore release is often the better option by the time bail is determined. In the past year, no one has been released on bail.[27]

The accused may appeal to the Appellate Instance Court to challenge the decision of the lower court in choosing pre-trial detention or the length of the detention. However, the Appellate Instance Court's decision is absolute.[28]

Guilty pleas are another available alternative to reduce pre-trial detention. However, guilty pleas are typically only used in special circumstances. Azerbaijan requires sincere repentance by the accused before a guilty plea can be effective. [29]

The best way to affect change in Azerbaijan's legislation is by appealing to the European Court of Human Rights. In the past year, a number of appeals have been sent to the Court pertaining to pre-trial detention. After the European Court of Human Rights issued decisions, the Azerbaijani Supreme Court held a special meeting to reevaluate local practices and issued an advisory note to the lower courts requesting the courts to employ alternatives to pre-trial detention.[30]

Georgia

The basic principles and procedures regarding criminal prosecution, pre-trial detention and criminal responsibility are regulated by the Constitution of Georgia, Criminal Code of Georgia, and Law on Probation and Code of Criminal Procedure of Georgia.[31]

The Code of Criminal Procedure of Georgia (CCP) is a legal act which specifically regulates procedure pertaining to pretrial detention and criminal responsibility. The current CCP was passed in 1999 by the Georgian Parliament. Since that date there have been many changes and amendments.[32]

A new Code of Criminal Procedure will take effect in October 2010.

The Constitution of Georgia

Article 18 (2):Deprivation of liberty or any other kind of restraint of liberty is inadmissible unless there is a court decision.

(3): A person may be detained only by an authorized officer and he/she must be presented to the court no later than 48 hours after arrest. The court must make a decision in the following 24 hours. In the event a court does not make a decision on the arrest or restraint of liberty, the detainee must be immediately released.

(7): A person who was unlawfully detained or arrested may request compensation.

Article 40 (1) A person is considered innocent until his/her guilt is proved by a court. (2) No one shall have to prove his/her innocence. The burden of proof is on the prosecution to show guilt.[33]

The Code of Criminal Procedure of Georgia: 1999 until October, 2010

Article 10: Presumption of Innocence

Article 159: (1) No one may be detained without an order of arrest issued by an authorized judicial body.

3. Arrest as a preventive measure may be condoned only when an individual has committed a crime carrying a sentence of 2 or more years. An individual may not be arrested as a preventive measure if ill, a juvenile, or above the age of 60 if a woman or 65 if a man. Additionally, a pregnant woman or a mother having a child less than a year old may not be arrested as a preventative measure.

Article 160: (1) A criminal prosecutor or an investigator with the permission of a criminal prosecutor is authorized to apply to the court to request an order of arrest. If there is sufficient grounds that the accused will flee, destroy evidence or commit a new crime, the prosecutor is authorized to detain.

Article 243: (1) The accused, his/her legal defender or a criminal prosecutor may submit a claim regarding pre-trial detention and request its termination, change or prolongation. The claim may be submitted only once to the upper instance of the court.[34]

New Code of Criminal Procedure: October 1, 2010

Important changes from current code:

  • Minimum bail has been raised to 1000 GEL (about 500 USD)
  • The general length for detention prior to judgment is 9 months. After 9 months, the accused must be released even if the court has not settled the charge, except when the accused has petitioned the court for additional time to prove innocence.
  • Pre-trial Detention must not exceed 60 days. Only the accused may petition to prolong detention.
  • Preventative arrest may only be appealed once. Once the Appellate Court has reviewed the appeal, the decision issued is final. The court is not required to conduct a trial or hear witnesses in making a decision.[35]

Requirements of "lawful, reasonable and necessary:" interpretation and impact

The terms 'reasonable' and 'necessary' are not strictly interpreted in accordance with the international human rights standards by the Georgian criminal procedure. The Code of Criminal Procedure provides for fixed terms of pre-trial detention. There is no evaluation of the reasonability of detention in each case; therefore the particular circumstances of a case are irrelevant in determining length of detention.[36]

Discrepancy between country's laws/codes, the international standards and practical implementation

Georgian criminal legislation does not include a right to a writ of habeas corpus. The absence of effective judicial review of detention may make other procedural guarantees ineffective.

Additionally, there are problems stemming from the lack of independence of the judicial authorities. The judiciary is intended to be an independent authority able to review the legality of detention by the international community. However, in practice, the Georgia judiciary is often governed by forces other than the strict interpretation of the law.[37]

Detainment

The minimum length of detention following arrest is 48 hours. During the 48 hours, the court must decide whether to charge the individual with a crime or release him/her. If the court decides to charge the individual, the judge must also set a length for pre-trial detention. Generally an individual is detained for a month initially, which may be extended twice. The first extension may only be for an additional month, but the second may be for two additional months. In total, pre-trial detention should not exceed four months.

Once the case goes to trial, an individual may be detained for five months. Therefore, at a maximum, an individual may be detained during both pre-trial and trial detention for a total of nine months. If the individual is found not guilty, the individual may request compensation for detention.

Both bail and personal recognizance are protections provided for in the Georgian Code of Criminal Procedure. However, there are issues with the granting of bail. In most cases, a prosecutor requests and is granted bail, however, an individual may not be released until at least 50% of the bail is paid. Many accused cannot afford to pay bail and remain in custody. Therefore, even though bail is frequently granted, in practice bail is an ineffective means of reducing pre-trial detention.

Plea Bargaining is also employed to reduce pre-trial detention. Often, accused who are granted bail but unable to pay are willing to make a plea in order to avoid longer detention. Plea Bargains have been available since 2005 in the Georgian Code of Criminal Procedure.[38]

Indonesia

According to Articles 20-21 of the Indonesia Criminal Procedure Law, pretrial detention is only justified in the following cases:

  • Subjective: There is a danger the suspect will:
    • flee,
    • destroy or remove evidence, and/or
    • repeat the crime.
  • Objective: the individual committed a crime that is penalized with 5 years imprisonment or more; or for a specific crime that carries a sentence of less than 5 years imprisonment but is based on Article 21: such as maltreatment, fraud, embezzlement, etc.[39]

Detention should be carried out if there is initial evidence. Additionally, the suspect should receive the arrest warrant, and his/her family should receive a receipt of the warrant.[40]

Requirements of "lawful, reasonable and necessary:" interpretation and impact

The "lawful, reasonable, and necessary" term is a standard clause in the detention warrant. However, the standard has never been clarified. Additionally, it is rarely contested as to whether a detainee fulfills the clauses. Therefore, for everyone arrested, the clauses must appear on the warrant but there is no requirement of proof.[41]

Discrepancy between country's laws/codes, the international standards and practical implementation

The national laws are in conformity with the international standards. However, arbitrary arrest still occurs regularly in Indonesia. In some cases, incommunicado detention occurs, which does not reflect international standards or domestic codes.[42]

Detainment

During a police investigation, a suspect can be detained for up to 20 days. This period can be extended with permission from a prosecutor for an additional 40 days.

During prosecution, a suspect can be detained up to 20 days, extending the previous detention period. This period can also be extended with permission from the Chief of District Court for an additional 30 days.[43]

Therefore, the total average period of pretrial detention is 110 days. However, according to the Indonesia Criminal Procedure Law, during both police investigation and prosecution, an individual can be detained for 30 days and additional time as needed if the accused is mentally or physically ill, or has been charged with a crime subject to 9 or more years in prison.[44]

Detainees may be released on bail or personal recognizance by the law; however, in practice, judges rarely release the accused prior to trial. The accused has the right to submit a bail appeal to the relevant legal authorities but bail is rarely granted and there are no other procedures available to challenge pre-trial detention.[45]

Philippines

Filipino law, in large part, complies with the threshold requirements of the United Nations with respect to pretrial detention. When the prosecutor finds probable cause to file the indictment against the accused before the appropriate trial court judge, the judge is required to look at the documents and interview witnesses before issuing a warrant of arrest.[46]

Hence, detention is lawful if it stems from a lawful order from a court with jurisdiction over the case, and is reasonable upon a finding of probable cause. Probable cause can be deduced when a crime is committed and the accused probably committed it. As to the 'necessary' element, detention is often the general rule when an indictment is filed. Authorities no longer determine whether or not detention is actually necessary.

There are also laws that prohibit torture and incommunicado detention -- in particular the Anti Torture Law, which was passed just last year, two full decades after the Philippines signed the Convention Against Torture.[47]

Requirements of "lawful, reasonable and necessary:" interpretation and impact

Generally interpreted to mean that detention is only done in accordance with the lawful orders of the judge; that the accused is apprised of his or her Miranda rights; that he is given the right to Counsel; that he has the right against self-incrimination, etc.[48]

Discrepancy between country's laws/codes, the international standards and practical implementation

In the towns of Bondoc Peninsula and Iloilo, the first official court document farmers receive are warrants of arrest. Hence, they are not properly apprised of the charges against them. They are not given a copy of the affidavits and are unable to file counter-affidavits. Many of them are arrested in the dead of the night, by a group composed of police and military elements.[49]

Detainment

Average detainment is approximately one month until an arraignment. Generally prisoners are able to be released on bail or personal recognizance. In cases not punishable by life imprisonment, bail is a fundamental right. For life imprisonment cases, including rape, robbery or murder, a bail hearing is required and a judge determines whether bail should be granted. Personal recognizance is available, but is not often granted.[50]

There are several ways to challenge prolonged client detention. Habeas Corpus is available to challenge illegal detainment. Both the accused and his or her representative or family member is able to file a writ of habeas corpus.[51] Additionally, a Motion to Quash the arrest warrant is available if there is evidence of irregularity or illegality in procedure. Finally, the defense can file a Motion to Dismiss for failure to undergo "barangay conciliation" mechanisms. Barangay conciliation is village conciliation which is required to small crimes committed in a barangay (village).[52]

Rwanda

Domestic Code

Organic Genocide Law: contains a section pertaining to confessions in exchange for reduced sentences. Confessions are encouraged by the law, but enforcement is somewhat arbitrary. More than 20,000 confessions have taken place since 1994, but only a small number have been processed due to the disconnect between the law and officials implementing the law.[53]

Alternative Justice Practices

Gisovu Project: the process of taking elderly, ill, persons without files, previously acquitted, or sentenced to a term outside of prison to their village to allow the villagers to air any grievances and make complaints. This is an effort to determine whether continued detention is needed. Approximately 30-40% of prisoners who were investigated in this manner were released.[54]

Gacaca Courts: grassroots justice. Combines participatory justice and reconciliation to form a local level court to judge genocide detainees. Gacaca law provides reduced sentences for cooperation and credits time served. However, lawyers are not able to officially participate. The exclusion of lawyers presents a problem for the accused, who are unaware of their rights. The public perception of corruption and wrongdoing within the Gacaca system is troubling, particularly because the system should work to alleviate the problem of having massive amounts of people held for years without trial.[55]

Courts

Local courts continue to try genocide related cases and for the most part meet international standards at trial, however the length of pretrial detention remains an issue.[56]

Kenya

Domestic Constitutional Law

Article 51 of the Constitution provides that “A person who is detained, held in custody or imprisoned under the law, retains all the rights and fundamental freedoms in the Bill of Rights, except to the extent that any particular right or a fundamental freedom is clearly incompatible with the fact that the person is detained, held in custody or imprisoned”

Freedom from Prolonged Pre-Trial Detention

The law puts in place mechanisms that ensure that a defendant is not subjected to unlawful pre-trial detention. These mechanisms include: (i) the granting of bail and, (ii) the requirement that the defendant be released promptly, if he/she is not charged within the time prescribed under law.

By virtue of Article 49 of the Constitution a defendant is to be charged or informed of the reason for the detention continuing, or to be released at the first court appearance. Similarly, Section 36 of the CPC provides that a person who is charged with a non-serious offence (i.e, all offenses other than murder, treason , armed robbery and attempted armed robbery) shall be released on bail if it is impracticable to bring him/her before an appropriate subordinate court within twenty-four hours after he has been so taken into custody,

Following an arrest with a warrant, the police officer or other official executing the warrant is required to bring the person arrested before the court without unnecessary delay. (See, section 108 of the CPC). In cases where a person is arrested without a warrant, Section 123 of the CPC requires that the person shall be granted bail or released upon executing a bond.

Practical Tips for Lawyers

When determining whether your client has been held in pre-trial detention unlawfully, it is important to weigh many factors. Use the questions provided below to determine whether you have a good claim for unlawful pre-trial detention.

  1. How do your country's laws reflect the UN's law of only allowing pretrial detention when detention is lawful, reasonable and necessary? Do the laws simply reflect the UN mandates or are they substantially different?
  2. How are the above terms "lawful, reasonable and necessary" interpreted by the justice system where your client is being held?
  3. How long has your client been held and what is the average period of pretrial detention there?
  4. Does your judicial system permit prisoners to be released on bail or for personal recognizance?
    1. If so, do you have a good claim for persuading a judge to release your client on bail or personal recognizance pending trial?
    2. How can your client obtain bail?
  5. If bail or release on personal recognizance aren't possibilities, or are rarely granted, what procedures are available to challenge the prolonged detention of your client? Examples:
    1. Plead Guilty (a typical remedy in common law systems): If the client confesses, how quickly will their confession be processed? And will they receive credit for time served?
    2. Interlocutory appeal of bail ruling (immediate pretrial appeal to a higher court)
    3. Motion to Dismiss for lack of speedy trial
    4. Dismissal of charges in the interest of justice
    5. Nullity Procedure
    6. Transfer of Venue to a court with a smaller docket. Perhaps a transfer to an alternative means of justice, such as the Gacaca courts in Rwanda?

Answering these questions on behalf of your client is a good way to measure whether the pre-trial detention is unlawful and whether your client's detention can be contested. However, as a good defense attorney, you should almost always challenge the legality of pre-trial detention, even if you believe that your client will lose.

Practical Methods of Reducing Pre-Trial Detention Rates

High pre-trial detention rates produce unnecessary suffering on behalf of defendants who are forced to remain in overcrowded and unsanitary conditions. These individuals force the government to incur unnecessary spending. Prison overcrowind can be mitigated by the construction of new facilities but the sustainable solution calls for more innovative approaches to pre-trial detention. The following are some of the new approaches used around the world to reduce or eliminate custodial sentencing:

  • Increased use of community service instead of imprisonment
  • Suspended sentences
  • Plea bargaining
  • Reprimand
  • Semi-Liberty - Defendant is permitted to maintain professional job, take care of family, receive education or training but must otherwise reside in prison [57]
  • Split sentences where an individual spends half time in prison and half outside of prison [58]
  • Methods of diverting cases from the criminal defense system and into rehabilitation programs.

Notes

  1. World Prison Brief Online (ICPS), http://www.kcl.ac.uk/depsta/law/research/icps/worldbrief/wpb_stats.php?area=all&category=wb_pretrial
  2. Anthony Nwapa, "Building and Sustaining Change: Pretrial Detention Reform in Nigeria" in Justice Initiatives: Pretrial Detention (New York: Open Society Institute, 2008), 86
  3. World Prison Brief Online (ICPS), http://www.kcl.ac.uk/depsta/law/research/icps/worldbrief/wpb_stats.php?area=all&category=wb_pretrial
  4. Eighth United Nations Congress on the Prevention of Crime and Treatment of Offenders.
  5. Eighth United Nations Congress on the Prevention of Crime and Treatment of Offenders.
  6. Centre for Human Rights, Geneva: Crime Prevention and Criminal Justice Branch, Vienna. Professional Training Series No. 3: Human Rights and Pre-trial Detention: A Handbook of International Standards relating to Pre-trial Detention. United Nations, New York and Geneva, 1994.
  7. The Human Rights Committee is a UN committee which monitors the implementation of the International Covenant on Civil and Political Rights by the 162 UN Member States.
  8. Centre for Human Rights, Geneva: Crime Prevention and Criminal Justice Branch, Vienna. Professional Training Series No. 3: Human Rights and Pre-trial Detention: A Handbook of International Standards relating to Pre-trial Detention. United Nations, New York and Geneva, 1994.
  9. Centre for Human Rights, Geneva: Crime Prevention and Criminal Justice Branch, Vienna. Professional Training Series No. 3: Human Rights and Pre-trial Detention: A Handbook of International Standards relating to Pre-trial Detention. United Nations, New York and Geneva, 1994.
  10. Centre for Human Rights, Geneva: Crime Prevention and Criminal Justice Branch, Vienna. Professional Training Series No. 3: Human Rights and Pre-trial Detention: A Handbook of International Standards relating to Pre-trial Detention. United Nations, New York and Geneva, 1994.
  11. Centre for Human Rights, Geneva: Crime Prevention and Criminal Justice Branch, Vienna. Professional Training Series No. 3: Human Rights and Pre-trial Detention: A Handbook of International Standards relating to Pre-trial Detention. United Nations, New York and Geneva, 1994.
  12. Centre for Human Rights, Geneva: Crime Prevention and Criminal Justice Branch, Vienna. Professional Training Series No. 3: Human Rights and Pre-trial Detention: A Handbook of International Standards relating to Pre-trial Detention. United Nations, New York and Geneva, 1994.
  13. Human Rights in the Administration of Justice: A Manual on Human Rights for Judges, Prosecutors and Lawyers; Human Rights and Arrest, Pre-Trial Detention and Administrative Detention. Chapter 5, pg. 191.
  14. Centre for Human Rights, Geneva: Crime Prevention and Criminal Justice Branch, Vienna. Professional Training Series No. 3: Human Rights and Pre-trial Detention: A Handbook of International Standards relating to Pre-trial Detention. United Nations, New York and Geneva, 1994. Footnote 44.
  15. Centre for Human Rights, Geneva: Crime Prevention and Criminal Justice Branch, Vienna. Professional Training Series No. 3: Human Rights and Pre-trial Detention: A Handbook of International Standards relating to Pre-trial Detention. United Nations, New York and Geneva, 1994.
  16. Centre for Human Rights, Geneva: Crime Prevention and Criminal Justice Branch, Vienna. Professional Training Series No. 3: Human Rights and Pre-trial Detention: A Handbook of International Standards relating to Pre-trial Detention. United Nations, New York and Geneva, 1994.
  17. Centre for Human Rights, Geneva: Crime Prevention and Criminal Justice Branch, Vienna. Professional Training Series No. 3: Human Rights and Pre-trial Detention: A Handbook of International Standards relating to Pre-trial Detention. United Nations, New York and Geneva, 1994.
  18. Centre for Human Rights, Geneva: Crime Prevention and Criminal Justice Branch, Vienna. Professional Training Series No. 3: Human Rights and Pre-trial Detention: A Handbook of International Standards relating to Pre-trial Detention. United Nations, New York and Geneva, 1994.
  19. Centre for Human Rights, Geneva: Crime Prevention and Criminal Justice Branch, Vienna. Professional Training Series No. 3: Human Rights and Pre-trial Detention: A Handbook of International Standards relating to Pre-trial Detention. United Nations, New York and Geneva, 1994.
  20. Centre for Human Rights, Geneva: Crime Prevention and Criminal Justice Branch, Vienna. Professional Training Series No. 3: Human Rights and Pre-trial Detention: A Handbook of International Standards relating to Pre-trial Detention. United Nations, New York and Geneva, 1994.
  21. Centre for Human Rights, Geneva: Crime Prevention and Criminal Justice Branch, Vienna. Professional Training Series No. 3: Human Rights and Pre-trial Detention: A Handbook of International Standards relating to Pre-trial Detention. United Nations, New York and Geneva, 1994.
  22. Centre for Human Rights, Geneva: Crime Prevention and Criminal Justice Branch, Vienna. Professional Training Series No. 3: Human Rights and Pre-trial Detention: A Handbook of International Standards relating to Pre-trial Detention. United Nations, New York and Geneva, 1994.
  23. International Bridges to Justice: Azerbaijani Justice Maker, July 2010
  24. International Bridges to Justice: Azerbaijani Justice Maker, July 2010
  25. International Bridges to Justice: Azerbaijani Justice Maker, July 2010
  26. International Bridges to Justice: Azerbaijani Justice Maker, July 2010
  27. International Bridges to Justice: Azerbaijani Justice Maker, July 2010
  28. International Bridges to Justice: Azerbaijani Justice Maker, July 2010
  29. International Bridges to Justice: Azerbaijani Justice Maker, July 2010
  30. International Bridges to Justice: Azerbaijani Justice Maker, July 2010
  31. International Bridges to Justice: Georgian Justice Maker, July 2010
  32. International Bridges to Justice: Georgian Justice Maker, July 2010
  33. International Bridges to Justice: Georgian Justice Maker, July 2010
  34. International Bridges to Justice: Georgian Justice Maker, July 2010
  35. International Bridges to Justice: Georgian Justice Maker, July 2010
  36. International Bridges to Justice: Georgian Justice Maker, July 2010
  37. International Bridges to Justice: Georgian Justice Maker, July 2010
  38. International Bridges to Justice: Georgian Justice Maker, July 2010
  39. International Bridges to Justice: Indonesian Justice Maker, July 2010
  40. International Bridges to Justice: Indonesian Justice Maker, July 2010
  41. International Bridges to Justice: Indonesian Justice Maker, July 2010
  42. International Bridges to Justice: Indonesian Justice Maker, July 2010
  43. International Bridges to Justice: Indonesian Justice Maker, July 2010
  44. International Bridges to Justice: Indonesian Justice Maker, July 2010
  45. International Bridges to Justice: Indonesian Justice Maker, July 2010
  46. International Bridges to Justice: Philippine Justice Maker, July 2010
  47. International Bridges to Justice: Philippine Justice Maker, July 2010
  48. International Bridges to Justice: Philippine Justice Maker, July 2010
  49. International Bridges to Justice: Philippine Justice Maker, July 2010
  50. International Bridges to Justice: Philippine Justice Maker, July 2010
  51. International Bridges to Justice: Philippine Justice Maker, July 2010
  52. International Bridges to Justice: Philippine Justice Maker, July 2010
  53. US State Department: Country Reports. Rwanda, 21 June 2010.
  54. US State Department: Country Reports. Rwanda, 21 June 2010.
  55. US State Department: Country Reports. Rwanda, 21 June 2010.
  56. US State Department: Country Reports. Rwanda, 21 June 2010.
  57. See, Cambodia Code of Criminal Procedure Articles 127-131
  58. See, Cambodia Code of Criminal Procedure Articles 132-135