Article 6 case-law on notification of rights: The principles established in these cases10 point to the need for clear notification of the (separate) rights to silence and to legal assistance at the point of arrest, 11 in such a way as to enable the suspect to understand them and exercise their rights. There is suggestion that oral notification is insufficient in some cases, and the case-law points to a need to take account of the specific characteristics of the individual (e.g. youth).12 Article 5/6 case-law on notification of accusations: The cases suggest that the suspect must be aware of the accusations at the point of questioning at the pre-trial stage.13 A separate strand of case-law concerns the requalification of offences at different stages of proceedings, e.g. on appeal; the principles require that the defence be notified of changes in qualification in such a way as to prepare a defence effectively; changes in qualification, even if operated by the court without inviting argument, are acceptable provided such requalification could be anticipated.14 Article 6 case-law on access to the case file: At the trial stage, the case-law usually concerns the withholding of information on public order grounds, and the case-law envisages a balancing of the interests at stake.15 At the pre-trial stage, there are a number of cases concerning the alleged prejudice caused to the defence by practical restrictions on access to the case file prior to trial, inhibiting trial preparation.16 At the stage of initial police interrogations, there is an open question as to whether Article 6 requires a certain amount of case material to be provided; one judgment suggests it might17 but, in general, this area is not sufficiently explored. Article 5 case-law on access to the case file: Case-law relating to Article 5(4) ECHR applies the ‘equality of arms’ principle drawn from Article 6 fair trial requirements to pre-trial detention decision-making, due to the serious nature of the decision at issue. Not all documents have to be disclosed, but those which are needed in order to challenge the lawfulness of detention must be provided.18 10 Zaichenko v. Russia, App. no. 39660/02 (Judgment of 18 February 2010), paragraph 38; Pishchalnikov v. Russia, App. no. 7025/04 (Judgment of 24 September 2009), paragraph 71. Stojkovic v. France and Belgium, App. no. 25303/08 (Judgment of 27 October 2011) (French only), paragraph 54; Panovits v. Cyprus, App. no. 4268/04 (Judgment of 11 December 2008), paragraph 65. 11 Case of Salduz v. Turkey, App. no. 36391/02 (Judgment of 27 November 2008), paragraphs 50-55. 12 Panovits v. Cyprus, cited above note 10, paragraphs 67, 73. 13 Case of Mattoccia v. Italy, App. no. 23969/94 (Judgment of 25 July 2000), paragraphs 63-64. 14 Case of I.H. and others v. Austria, App. no. 42780/98 (Judgment of 20 April 2006), paragraphs 36-38. 15 Case of Jasper v. The United Kingdom, App. no. 27052/95 (Judgment of 16 February 2000), paragraph 52. 16 Case of Iglin v. Ukraine, App. no. 39908/05 (Judgment of 12 January 2012), paragraph 60; Case of Vyerentsov v. Ukraine, App. no. 20372/11, (Judgment of 11 April 2013), paragraphs 73-76; Case of Öcalan v. Turkey, App. no. 46221/99, (Judgment of 12 May 2005), paragraph 142. 17 Case of Sapan v. Turkey, App. no. 17252/09 (Judgment of 20 September 2011), paragraph 21 18 Case of Lamy v. Belgium, App. no. 10444/83, (Judgment of 30 March 1989), paragraph 29; Case of Schops v. Germany, App. no. 25116/94 (Judgment of 13 February 2001), paragraph 44. 8