Pre-Trial Detention

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Background

Pre-trial detention is when a person is held by a governing body for an offense committed against the laws of the state prior to a trial. Pre-trial detention remains a problem around the world despite international standards and domestic laws cautioning against pre-trial detention. Many times prisoners are held for years on end without any hope or opportunity for trial. While there are multiple issues from pre-trial detention ranging from inhumane conditions to the length of detention, this page will focus primarily on the determination and length of detention.

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. a danger that the course of justice will be seriously interfered with if the alleged offender is free.[1]


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, alternatives should be employed 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.[2]


International Covenant on Civil and Political Rights

Under Article 9(3): "It shall not be the general rule that 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."[3]

The above provision, along with the Universal Declaration of Human Rights has been interpreted by the UN Human Rights Committee[4] 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,
  • interference with evidence or
  • 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.[5]

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.[6] 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.[7] 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.[8]

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.[9] A reasonable amount of time is assessed in each individual case.[10]

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.[11]

Furthermore, the Committee has provided guidelines for States regarding pre-trial detention.[12] 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.[13]

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.[14] 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 habeas corpus or amparo proceedings. For effective implementation, the detainee must have notice of why he or she is being held and access to legal counsel.[15]

The Universal Declaration of Human Rights establishes in Article 8, 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."[16]

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 person without adequate means. The detaining authority shall produce without unreasonable delay the detained person before the reviewing authority.[17]

The Human Rights Committee has interpreted the 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.[18]

Article 9(4) applies to all detention, including detention ordered by an administrative body or authority.[19]

Case Studies

Azerbaijan

In Azerbaijan, pre-trial detention is the preferred means of dealing with accused who have been charged with a crime. Though alternatives such as home arrest, bail, and police supervision exist, pre-trial detention is overwhelmingly preferred, especially for those charged with grave crimes.[20]

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 the judicial system.[21]

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

There is not much discrepancy between the codes and the international standards. However, there is a serious difference in the practical implementation of the laws.[22]

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.[23]


   6) Does your judicial system permit prisoners to be released on bail or their personal recognizance?
   Releasing on bail exists in our law system; however this is rarely applied in the practice. The court can solve the possibility of releasing the accused person leaving as deposit at the same time with issuing a decision regarding the arrest and the court defines the amount of the deposit if the releasing is possible.
   a)      If so, do judges regularly release accused on bail or personal recognizance pending a trial? 

No. it happens rarely in our juridical system.

   b)      How does an accused person obtain bail? 

Person accused on grave crime can be released instead of certain sum and/ or personal bail. The organ carrying out the criminal process considering the possibility to choose pre-trial detention on questionable or accused person in the case of the bail is confident, as well as personal bail or organizational bail introduces the applicant, as well as the legal person's representative with the content of the doubt or the accusation and warns the guarantor regarding the responsibility. After this the applicant can confirm or deny his/her request.

   c)      How many accused persons were granted bail in the last year?
   According to our information, no person was released on bail last year.
   7) If there is not bail or release on personal recognizance, or they are rarely granted, what procedures are available to challenge prolonged detention of your client?
   The criminal process's sides can appeal to Appellate Instance Court against the decision of the court on choosing pre-trial detention or refusing to choose the pre-trial detention.  Appellate instance court's decision on this issue is resolute.
               Examples:
   a)      Plead Guilty (a typical remedy in common law systems):  If the client confesses, how quickly is the confession processed?

Plead guilty, sincerely repentance is considered as extenuating cases while sentencing, however these are not considered as extenuating cases in our juridical system in use.

   b)      Interlocutory appeal of bail ruling (immediate pretrial appeal to a higher court)

During the hearing, the court can change and cancel the pre-trial detention on accused person considering the expressions of the accused person and his\her representative, as well as the opinions of state plaintiff, the injured person (special plaintiff).

   c)      Motion to Dismiss for lack of speedy trial

The term is changeable according to the cases of the crime.

   d)     Dismissal of charges in the interest of justice

Dismissal of charge happened rarely in the interest of justice . It is carried out on the cases that do not have special importance.

   e)      Nullity Procedure

The court can cancel the pre-trial detention if the accused person is sick or in the other cases.

   f)       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?

It is impossible to apply such experience in Azerbaijan.

   g)      Any other procedural mechanisms by which you could improve the outcome of your client's case?

We appeal to the European Court of Human Rights if Local Courts issues unfair decisions on client's case. Number of appeals to European Court of Human Rights increased to improve the outcome of different cases.



   8) If you have adopted any strategies in the past to reduce pretrial detention rates, please explain and identify whether the strategy was successful.  If not, how could the strategy have been improved?
   Number of appeals should be sent to the European Court of Human Rights to reduce the pretrial detention rates. A lot of appeals were sent to the European Court of Human Rights regarding pretrial detention in the recent years. After the European Court of Human Rights' relevant decisions Azerbaijani Supreme Court held special colleague's meeting and suggested to the lower instances courts to prefer to choose other forms of detention.  
   9) Is it possible to file a class action lawsuit on behalf of all pretrial detainees that have been held beyond reasonable limits?
   Each person can appeal on behalf of his\her name.
   10) What other strategies (media, roundtables, etc) can be effective means to reduce pretrial detention rates for more than one defendant at a time?
   Each person can appeal to high related organs (Supreme Court, president etc.). 

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.[24]

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.[25]

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.[26]


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.[27]


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. One 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.[28]


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

The terms reasonable and necessary are not strictly interpreted in accord 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.[29]


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.[30]


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. 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 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 the bail and they remain in custody. Therefore, even though bail is granted many times, in practice bail is not an effective means of reducing pre-trial detention.

Plea Bargaining is also employed to reduce pre-trial detention. Many times, 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.[31]


Indonesia

According to Article 20-21 of the Indonesia Criminal Procedure Law, pretrial detention can only be conducted based on two reasons:

  • Subjective: There is a danger the suspect will:
    • flee,
    • destroy or remove evidence, and/or
    • repeat the crime.
  • Objective: individual committed a crime that is charged 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.[32]

Detention should be carried out if there is initial evidence; and the suspect should receive the arrest warrant; and his/her family receives a receipt of the warrant.[33]


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

The "lawful, reasonable, and necessary" term is a standard clause in the detention warrant. However, it has never been clarified regarding the standard. 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.[34]


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

The national laws are in conformity with the international standards. However, the arbitrary arrest still occurs regularly in Indonesia. In some cases, incommunicado detention occurs, which does not reflect international standards or domestic codes.[35]


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.[36]

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.[37]

Detainees may be released on bail or personal recognizance by the law, however, in practice judges rarely release 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 not other procedures available to challenge pre-trial detention.[38]


Philippines

Philippine 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.[39]

Hence, detention is lawful (done only upon lawful order from a court with jurisdiction over the case) and reasonable (upon a finding of probable cause, i.e., that a crime was committed and the accused probably committed it). As to necessary, 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, or two full decades after the Philippines signed the Convention Against Torture.[40]


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.[41]


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 goons, police and military elements.[42]


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.[43]

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 of family member is able to file a writ of habeas corpus.[44] 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 villiga conciliation which is required to small crimes committed in a barangay (village).[45]


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.[46]


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.[47]

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 not aware 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 massive amounts of people held for years without trial.[48]


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.[49]


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 requirements of pretrial detention only 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 their 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 there is not bail or release on personal recognizance, or they 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 additionally 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.

Notes

  1. Eighth United Nations Congress on the Prevention of Crime and Treatment of Offenders.
  2. Eighth United Nations Congress on the Prevention of Crime and Treatment of Offenders.
  3. 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.
  4. 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.
  5. 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.
  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. 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.
  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. 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.
  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. Footnote 44.
  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. 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.
  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.
  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. International Bridges to Justice: Azerbaijan Justice Maker, July 2010
  21. International Bridges to Justice: Azerbaijan Justice Maker, July 2010
  22. International Bridges to Justice: Azerbaijan Justice Maker, July 2010
  23. International Bridges to Justice: Azerbaijan Justice Maker, July 2010
  24. International Bridges to Justice: Georgian Justice Maker, July 2010
  25. International Bridges to Justice: Georgian Justice Maker, July 2010
  26. International Bridges to Justice: Georgian Justice Maker, July 2010
  27. International Bridges to Justice: Georgian Justice Maker, July 2010
  28. International Bridges to Justice: Georgian Justice Maker, July 2010
  29. International Bridges to Justice: Georgian Justice Maker, July 2010
  30. International Bridges to Justice: Georgian Justice Maker, July 2010
  31. International Bridges to Justice: Georgian Justice Maker, July 2010
  32. International Bridges to Justice: Indonesian Justice Maker, July 2010
  33. International Bridges to Justice: Indonesian Justice Maker, July 2010
  34. International Bridges to Justice: Indonesian Justice Maker, July 2010
  35. International Bridges to Justice: Indonesian Justice Maker, July 2010
  36. International Bridges to Justice: Indonesian Justice Maker, July 2010
  37. International Bridges to Justice: Indonesian Justice Maker, July 2010
  38. International Bridges to Justice: Indonesian Justice Maker, July 2010
  39. International Bridges to Justice: Philippine Justice Maker, July 2010
  40. International Bridges to Justice: Philippine Justice Maker, July 2010
  41. International Bridges to Justice: Philippine Justice Maker, July 2010
  42. International Bridges to Justice: Philippine Justice Maker, July 2010
  43. International Bridges to Justice: Philippine Justice Maker, July 2010
  44. International Bridges to Justice: Philippine Justice Maker, July 2010
  45. International Bridges to Justice: Philippine Justice Maker, July 2010
  46. US State Department: Country Reports. Rwanda, 21 June 2010.
  47. US State Department: Country Reports. Rwanda, 21 June 2010.
  48. US State Department: Country Reports. Rwanda, 21 June 2010.
  49. US State Department: Country Reports. Rwanda, 21 June 2010.