   If the offence can be committed by everyone and not just a restricted group, such as doctors or accountants, and the purpose is to punish and deter;595 Whether the proceedings are instituted by a public body with statutory powers of enforcement;596 Whether the imposition of a penalty is dependent on a finding of culpability.597 54. As to the purpose, character or severity of the penalty, if the penalty is imprisonment, or can include imprisonment, such as imprisonment in default of a fine, this is likely to be a criminal charge.598 This will include situations where the offence is part of a State’s separate administrative enforcement regime, not the criminal justice system.599 Financial penalties may also amount to a criminal charge, for example fines, tax penalties, particularly if they are high.600 By contrast, freezing of assets,601 and regulatory offences which can only result in disqualification are unlikely to be regarded as criminal. The severity of the penalty will be the decisive factor in offences against military and prison discipline. H. Civil rights and obligations 55. Article 14 ICCPR provides for rights of access to the courts in relation to civil proceedings.602 The Human Rights Committee has noted that the concept of ‘suit at law’/’droits et obligations de caractère civil’ (in French) and its interpretation in other languages depends on the ‘nature of the right in question rather than on the status of one of the parties or the particular forum provided by domestic legal systems for the determination of particular rights’.603 56. In order to determine whether the proceedings are ‘civil’ and therefore subject to the protection of the relevant treaty, one first needs to look at the extent of the right or obligation in national law. 57. The Human Rights Committee’s General Comment 32 provides a useful summary of suits at law or civil proceedings. These include: 595 Benham v UK, , para 56; Weber v Switzerland, [1990] ECHR 13, para 33; Demicoli v Malta, [1991] 14 EHRR 47, para 33. 596 Ozturk v Germany, 24 February 1984. 597 Benham v UK UK [1996] ECHR 22 598 Engel v Netherlands, [1976] ECHR 3, para 81. 599 Ozturk v Germany, 24 February 1984. 600 Lauko v Slovakia, [1998] ECHR 82, para 58. 601 Human Rights Committee, Communication 1472/2006, Sayadi and Vinck v Belgium, 22 October 2008, para 10.11. 602 There is no specific reference in the Arab Charter to civil proceedings, although Article 12 refers generally to equality before the courts and tribunals. Article 30 of the Palestinian Basic Law provides for a right to submit a case to court. 603 General Comment No.32, CCPR/C/GC/32 (2007), para 16; see also Communication No. 112/1981, Y.L. v. Canada, paras. 9.1 and 9.2. Kaur v Canada, Communication 1455/2006, UN Doc.CCPR/C/OP/94/D/1455/2006 (2008), para 7.5. 108