Chapter vi  Equality of Arms and Rights to a Fair Hearing 119 his defence, and also for the conduct of that defence in trial. In contrast, the ECHR only has one reference to the right to a lawyer, in Article 6(3)(c), which is the right to defend oneself in person or through legal assistance of one’s choosing. The European Court of Human Rights has read Article 6(3)(b) and (c) together to imply a right to a lawyer during the preparation stage of proceedings.479 The right to communicate with counsel of one’s choosing in the preparation of one’s defence is a right that is limited to criminal proceedings, although there might arise a comparable right to legal assistance in civil proceedings if to do otherwise would create an inequality in the ability of the parties to present their case (See also 6.1.2). In the criminal context, the right requires that the accused is granted prompt access to counsel.480 It also requires that counsel is able to meet their clients in private and to communicate with the accused in conditions that fully respect the confidentiality of their communications (See also 6.6.6).481 Denying a person access to legal counsel has been concluded to amount to a failure to permit the adequate preparation of a defence case.482 Denial of representation when requested during an interrogation also constitutes a violation of rights under Article 14(3)(b) of the ICCPR.483 The European Court of Human Rights considers that, as a rule, access to a lawyer should be provided as from the first interrogation of a suspect by the police.484 The Court has underlined the importance of the investigation stage for the preparation of criminal proceedings. During this phase, the accused often finds her/himself in a particularly vulnerable position that can only be properly counter-balanced by the assistance of a lawyer, whose task it is, among other things, to help ensure adherence with the right of an accused not to incriminate her/himself (See also 5.2). The Court has also noted the recommendations of the European Committee for the Prevention of Torture and Inhuman or Degrading Treatment or Punishment, in which the Committee repeatedly stated that the right of a detainee to have access to legal advice is a fundamental safeguard against ill-treatment.485 The right of access to counsel during the interrogation may be exceptionally restricted only for “compelling reasons”. However, such restrictions – whatever their justification – must not unduly prejudice the rights of an accused to defence. Therefore, the denial of access to counsel during the early stage of the investigation amounts to violation of Article 14 of the ICCPR and Article 6 of the ECHR, where the rights of the defence will, in principle, be irretrievably 479 Campbell and Fell v the United Kingdom [1984] ECHR 8, para 98. 480 UN Human Rights Committee, CCPR General Comment 32 (2007), para 34. 481 UN Human Rights Committee, CCPR General Comment 32 (2007), para 34 482 Ramirez v Uruguay, HRC Communication 4/1977, UN Doc CCPR/C/10/D/4/1977 (1980), para 18; and Sequeira v Uruguay, HRC Communication 6/1977, UN Doc CCPR/C/OP/1 at 52 (1984), para 16. 483 Gridin v Russian Federation, HRC Communication 770/1997, UN Doc CCPR/C/69/D/770/1997 (2000), para 8.5; Penarrieta and Others v Bolivia, HRC Communication 176/1984, UN Doc CCPR/C/31/D/176/1984 (1988), para 16; and Lyashkevich v Uzbekistan, HRC Communication 1552/2007, UN Doc CCPR/ C/98/D/1552/2007 (2010), para 9.4. 484 John Murray v the United Kingdom [1996] ECHR 3, para 63; Yoldaş v Turkey [2010] ECHR 1620, para 49, available in French only. 485 Salduz v Turkey [2008] ECHR 1542, para 54.