Chapter vi  Equality of Arms and Rights to a Fair Hearing 121 to adequate time to prepare one’s defence must be balanced against the right to trial within a reasonable time (See also 6.4). In the context of criminal proceedings, it is important that the defence has the opportunity to familiarize itself with the documentary evidence against an accused, by way of full and prompt disclosure (See also 6.3.5). In Bee v Equatorial Guinea, for example, the Human Rights Committee found a violation of Article 14(1) and (3) of the ICCPR in circumstances where defendants in a criminal hearing were not notified of the grounds for the charges against them until two days before the trial, depriving them of sufficient time to prepare their defence and making it impossible for them to select their defence lawyers.493 In Albert and Le Compte v Belgium, however, a period of 15 days between notice of disciplinary charges (of providing spurious medical certificates of unfitness) and an investigative hearing was found by the European Court of Human Rights to be sufficient in the circumstances, given the lack of complexity of the case.494 A period of 21 days to examine 49 pages of a case file was also considered to be adequate time,495 while a period of only 16 days before trial to review and consider the implication of 17,000 pages of case files was found to be inadequate time to prepare and, thus, in violation of Article 6(3)(b) of the ECHR.496 Providing newly-appointed counsel in a murder trial with just four hours to confer with the accused and prepare the defence case was found by the Human Rights Committee to violate Article 14(3)(b) of the ICCPR.497 The right to adequate time to prepare may entitle one of the parties to request and receive an adjournment of proceedings. The Human Rights Committee has considered that courts are under an obligation to grant reasonable requests for adjournment, particularly when an accused is charged with a serious criminal offence and additional time for preparation of the defence is needed.498 This has been found to be particularly important in capital cases, i.e., where a sentence of death could result from conviction, since to do otherwise would not be compatible with the interests of justice.499 An obligation to grant an adjournment of proceedings might also arise where delays have been caused as a result of conduct by the State or by the party who is not seeking the adjournment.500 The Committee has noted that 493 Bee v Equatorial Guinea, HRC Communications 1152/2003 and 1190/2003, UN Doc CCPR/ C/85/D/1152&1190/2003 (2005), para 6.3. 494 Albert and Le Compte v Belgium [1983] ECHR 1, para 41. 495 Kremzow v Austria [1993] ECHR 40, para 48. 496 Öcalan v Turkey [2005] ECHR 282, paras 147–148. 497 Smith v Jamaica, HRC Communication 282/1988, UN Doc CCPR/C/47/D/282/1988 (1993), para 10.4. See also Reid v Jamaica, HRC Communication 355/1989, UN Doc CCPR/C/51/D/355/1989 (1994), para 14.2. 498 UN Human Rights Committee, CCPR General Comment 32 (2007), para 32; Kurbanov v Tajikistan, HRC Communication 1096/2002, UN Doc CCPR/C/79/D/1096/2002 (2003), para 7.3. 499 See, for example, Phillip v Trinidad and Tobago, HRC Communication 594/1992, UN Doc CCPR/ C/64/D/594/1992 (1998), para 7.2; and Chan v Guyana, HRC Communication 913/2000, UN Doc CCPR/ C/85/D/913/2000 (2006), para 6.3. 500 Domenichini v Italy [1996] ECHR 55, para 39.