In relation to Article 5(2) ECHR, the ECtHR has developed a general approach whereby the person must be provided with a sufficiently clear understanding of what is alleged against them, in appropriate language, in order for them to understand the basis of their detention: Paragraph 2 of Article 5 (art. 5-2) contains the elementary safeguard that any person arrested should know why he is being deprived of his liberty. This provision is an integral part of the scheme of protection afforded by Article 5 (…) [B]y virtue of paragraph 2 (…) any person arrested must be told, in simple, non-technical language that he can understand, the essential legal and factual grounds for his arrest, so as to be able, if he sees fit, to apply to a court to challenge its lawfulness in accordance with paragraph 4.31 Applying this approach in criminal cases, the ECtHR has reached some relevant findings, pointing to the need for factual statements, prompt delivery of reasons and accommodation to the needs of the particular suspect:    Violation due to the provision of written orders indicating only the relevant legal provisions, without mentioning any factual circumstances;32 Violation due to delay in providing full reasons, noting that the description of the legal provisions may not have been sufficient absent an opportunity for the suspect to familiarise himself with the legal provisions ;33 Violation due to the questioning of an arrested suspect who was deaf, dumb (voiceless), illiterate and had a mental disability, using an official sign-language interpreter when the suspect did not use that form of sign language, without having recourse to the assistance of the suspect’s mother.34 In relation to Article 6 ECHR, the ECtHR has developed a standard statement of principle has been developed, specifying a right of information to enable defence at all stages of the process: The provisions of paragraph 3 (a) of Article 6 point to the need for special attention to be paid to the notification of the “accusation” to the defendant. Particulars of the offence play a crucial role in the criminal process, in that it is from the moment of their service that the suspect is formally put on written notice of the factual and legal basis of the charges against him (…). Article 6 §3 (a) of the Convention affords the defendant the right to be informed not only of the “cause” of the accusation, that is to say the acts he is alleged to have committed and on which the accusation is based, but also the legal characterisation given to those acts. That information should be detailed. 35 The ECtHR has applied these principles to various situations, relating to different stages of proceedings, always asking whether the alleged failure to notify the accusation prejudiced the fairness of the whole proceedings. Here are some recent examples: 31 Fox and others v. United Kingdom App. no 12244/86 (Judgment of 30 August 1990), paragraph 40. Petkov and Profirov v. Bulgaria App. no 50027/08 (Judgment of 24 June 2014), paragraph 61. 33 Kortesis v. Greece App. no 60593/10 (Judgment of 12 June 2012), paragraph 61. 34 Z.H. v. Hungary App. no 28973/11 (Judgment of 8 November 2012), paragraphs 42-43. 35 Case of Kamasinski v. Austria, App. no. 9783/82 (Judgment of 19 December 1989), paragraph 79; Case of Pélissier and Sassi v. France, App. no. 25444/94 (Judgment of 25 March 1999), paragraphs 51-52, Mattocia v. Italy, cited above note 13, paragraph 58. 32 25