120 Legal Digest of International Fair Trial Rights prejudiced as, for instance, when incriminating statements made during police interrogation without access to a lawyer are used for a conviction (See also 5.2).486 In John Murray v the United Kingdom, a case falling under anti-terrorism legislation in Northern Ireland, the European Court of Human Rights found that to deny access to a lawyer for the first 48 hours of police questioning amounted to a violation of Article 6 (6) in a situation where the rights of the defence may well have been irretrievably prejudiced. The Court considered that, under domestic rules, the accused was confronted with a fundamental dilemma relating to his defence. If he were to choose to remain silent, adverse inferences could have been drawn against him (See also 5.2.4). On the other hand, if he were to opt to break his silence during the course of interrogation, he would have run the risk of prejudicing his defence. Under such conditions, the European Court found that the concept of fairness of the trial requires that the accused has the benefit of a lawyer’s assistance already at the initial stages of police interrogation.487 The exercise of the right to communicate with counsel is all the more important when the right’s holder is detained or imprisoned.488 In this case, the right may not be suspended or restricted, save in exceptional circumstances, to be specified by law or lawful regulations, when it is considered indispensable by a judicial or other authority in order to maintain security and good order. 489 In any circumstances, the prohibition on incommunicado detention necessitates that the right shall not be denied for more than a matter of days.490 6.3.4 The right to adequate time to prepare one’s case The right to have adequate time for the preparation of one’s defence, which applies to detained or imprisoned persons as well, is directly linked to the right to be “promptly” informed of criminal charges (See also 6.3.1) and to right to communicate with counsel (See also 6.3.3).491Determination of what constitutes “adequate time” to prepare one’s case requires an assessment of the individual circumstances of each case, including the nature and the complexity of the case and the stage that the proceedings have reached.492 The right 486 Salduz v Turkey [2008] ECHR 1542, para 55; Yoldaş v Turkey [2010] ECHR 1620, para 49, available in French only. 487 John Murray v the United Kingdom [1996] ECHR 3, para 66. See also, Magee v the United Kingdom [2000] ECHR 216, para 39, 44. 488 UN Body of Principles for the Protection of All Persons under Any Form of Detention or Imprisonment, Principle 18 (1) adopted by the UN General Assembly on 9 December 1988. 489 UN Body of Principles for the Protection of All Persons under Any Form of Detention or Imprisonment, Principle 18 (3) adopted by the UN General Assembly on 9 December 1988. 490 UN Body of Principles for the Protection of All Persons under Any Form of Detention or Imprisonment, Principle 15 adopted by the UN General Assembly on 9 December 1988. 491 UN Body of Principles for the Protection of All Persons under Any Form of Detention or Imprisonment, Principle 18 (2) adopted by the UN General Assembly on 9 December 1988. 492 Albert and Le Compte v Belgium [1983] ECHR 1, para 41; Hibbert v Jamaica, HRC Communication 293/1988, UN Doc CCPR/C/45/D/293/1988 (1992), para 7.4; and Williams v Jamaica, HRC Communication 561/1993, UN Doc CCPR/C/59/D/561/1993 (1997), para 9.3.