Chapter iv  Right to a Public Hearing 85 way as legal impediments.330 This may result, for example, from a lack of publicity of hearings (See also 4.2.1), an inaccessible venue (See also 4.2.2), insufficient courtroom space (See also 4.2.3) or the application of unreasonable conditions on entry into the courtroom (See also 4.2.4). 4.2.1 Publicity of hearings The publicity of hearings ensures the transparency of proceedings and, thus, provides an important safeguard for the interests of the individual and of society at large. The European Court of Human Rights has stated that “a trial complies with the requirement of publicity only if the public is able to obtain information about its date and place”.331 Therefore, courts must make information available to the public regarding the time and venue of oral hearings.332 Trial schedules should be regularly displayed either outside the courthouse, in the entry of courthouse or in the courtrooms. Information should include details concerning the date and location of hearings, as well as of the court responsible for the hearing. 4.2.2 Location of hearings In order to render public access to a hearing both practical and effective, the place of hearing must be easily accessible to the public. The exclusion of the public from the hearing held in prison facilities is justifiable according to the ECHR only for disciplinary proceedings (See also 4.1.3). As observed by the European Court of Human Rights in Hummatov v Azerbaijan, “the holding of a trial outside a regular courtroom, in particular in a place like a prison, to which the general public in principle has no access, presents a serious obstacle to its public character. In such a case, the State is under an obligation to take compensatory measures in order to ensure that the public and the media are duly informed about the place of the hearing and are granted effective access”.333 The Court concluded, in that case, that the failure to provide a regular shuttle service to the hearing venue had a clearly discouraging effect on potential spectators wishing to attend the applicant’s trial and held that there had been a violation of Article 6(1) of the ECHR.334 4.2.3 Courtroom space Both domestic legislation and judicial practice must provide for the possibility of the public attending a hearing, if members of the public so wish.335 In order to facilitate this, the Human Rights Committee has observed that courts must make information on the time 330 Airey v Ireland [1979] ECHR 3, para 25; Artico v Italy [1980] ECHR 4, para 33; Hummatov v Azerbaijan [2007] ECHR 1026, para 144; and Andrejeva v Latvia [2009] ECHR 297, para 98. 331 Riepan v Austria [2000] ECHR 575, para 29. See also Van Meurs v the Netherlands, HRC Communication 215/1986, UN Doc CCPR/C/39/D/215/1986 (1990), para 6.2. 332 Van Meurs v the Netherlands, HRC Communication 215/1986, UN Doc CCPR/C/39/D/215/1986 (1990), para 6.2; Hummatov v Azerbaijan [2007] ECHR 1026, para 144. 333 Hummatov v Azerbaijan [2007] ECHR 1026, para 144. See also Riepan v Austria [2000] ECHR 575, paras 29–31. 334 Hummatov v Azerbaijan [2007] ECHR 1026, paras 140–152. 335 Van Meurs v the Netherlands, HRC Communication 215/1986, UN Doc CCPR/C/39/D/215/1986 (1990), para 6.1.