86 Legal Digest of International Fair Trial Rights and venue of the oral hearings available to the public and provide for adequate facilities for the attendance of interested members of the public, within reasonable (necessary and proportional) limits.336 This will need to take into account various factors, such as the potential public interest in the case and the duration of the oral hearing. In Marinich v Belarus, for example, the Human Rights Committee found a violation of Article 14(1) of the ICCPR in a situation where a small hearing room, able to accommodate only 12 people, was used for the hearing of a public figure in respect of which it was reasonable to assume that there would be significant public interest.337 The Human Rights Committee has acknowledged, however, that failure to make large courtrooms available does not constitute a violation of the right to a public hearing if no interested member of the public has actually been barred from attending an oral hearing.338 4.2.4 Entry conditions If a hearing is open, access to the courtroom must be available to the general public, including the media, and must not be restricted to a particular category of persons.339 This means that a hearing will be treated as not having been held in public if the access by the general public is hindered, notwithstanding the presence of trial monitors. The imposition of strict entry conditions, combined with an overall environment of surveillance and secrecy, can amount to a violation of the right to a public hearing. In Marinich v Belarus, for example, representatives of political parties and NGOs were effectively barred from the courtroom – even though hearings were declared to be open to the public – in a situation where the court building was surrounded by police who prevented people from approaching the building and where security services were constantly present in the building and recorded the proceedings.340 Media representatives should be allowed to report on the hearing, although it is permissible for judicial authorities to restrict the use of cameras and audio-visual recordings. It is also compatible with the right to a public hearing for authorities to require reasonable identity and security checks if security concerns require this.341 336 Van Meurs v the Netherlands, HRC Communication 215/1986, UN Doc CCPR/C/39/D/215/1986 (1990), para 6.2. 337 Marinich v Belarus, HRC Communication 1502/2006, UN Doc CCPR/C/99/D/1502/2006 (2010), para 10.5. 338 Marinich v Belarus, HRC Communication 1502/2006, UN Doc CCPR/C/99/D/1502/2006 (2010), para 10.5. 339 UN Human Rights Committee, CCPR General Comment 32 (2007), para 29. 340 Marinich v Belarus, HRC Communication 1502/2006, UN Doc CCPR/C/99/D/1502/2006 (2010), paras 2.16, 10.5. 341 Hummatov v Azerbaijan [2007] ECHR 1026, para 143.