217. Similarly, the African Commission noted in Zimbabwe Human Rights NGO Forum v Zimbabwe77, that “The protection afforded by Article 7 is AC HP R not limited to the protection of the rights of arrested and detained persons but encompasses the right of every individual to access the relevant judicial bodies competent to have their causes heard and be granted adequate relief.” 218. To strengthen the spirit of Articles 7 and 26 of the African Charter, the African Commission adopted the Principles and Guidelines on the Right to Fair Trial and Legal Assistance in Africa (the Principles and Guidelines on the Right to Fair Trial),78 to assist States Parties to the African Charter in their guarantee of the right to fair trial as enshrined in the African Charter. One of the essential elements of a fair hearing under the Principles include; “An entitlement to an appeal to a higher judicial body.”79 It also provides that, “The right to appeal should provide a 77 78 79 Communication 245/2002 - Zimbabwe Human Rights NGO Forum v Zimbabwe. See also the Recommendation on the Respect and Strengthening of the Independence of the Judiciary adopted by the African Commission during its 19th Session, which took place in Ouagadougou, Burkina Faso in 1996. This Recommendation calls upon States Parties to the African Charter, to meet certain minimum standards to guarantee the independence of judiciaries in the region, including inter alia; the recognition of universal principles of judicial independence; and urging governments to eliminate any legislation affecting judicial independence. Ibid Section 2(j). 63