58 Legal Digest of International Fair Trial Rights The establishment of the International Criminal Court (ICC), for instance, imposes on States a duty to establish specific courts or extend jurisdiction of an existing court(s). In the case of Croatia, for example, the ratification of the Rome Statute on the ICC was followed by the adoption of legislation establishing four specialized war crimes courts. 3.3 Independent and impartial tribunal The independence and impartiality of a tribunal is a central pillar of the right to a fair hearing.197 In implementing the relevant standards and commitments, OSCE participating States have agreed to ensure that the independence of the judiciary is guaranteed and enshrined in the constitution or the law of the country and is respected in practice, paying particular attention to the Basic Principles on the Independence of the Judiciary.198 Moreover, the OSCE has published the Kyiv Recommendations on Judicial Independence in Eastern Europe, South Caucasus and Central Asia, to assist participating States in strengthening the independence of their judiciaries, particularly in the areas of judicial administration, the selection of judges and their accountability.199 The requirement of independence means, in general terms, that tribunals should be free from any form of direct or indirect influence, whether this comes from the government, from the parties in the proceedings or from third parties, such as the media (See also .3.1).200 Impartiality is a guarantee that is linked to the principle of equality before courts and tribunals (See also 2.2) and involves the idea that everyone should be treated the same. It requires that judicial officers exercise their function without personal bias or prejudice and in a manner that offers sufficient guarantees to exclude any legitimate doubt of their impartiality (See also 3.3.2). The requirements of independence and impartiality apply to juries as well as judges (See also 3.3.3) Although independence and impartiality each hold different meanings and give rise to vary­ ing implications, the two requirements are very often dealt with together by the Human Rights Committee and the European Court of Human Rights.201 This becomes particularly evident when considering the subject of specialized courts, such as military tribunals (See 197 Delcourt v Belgium [1970] ECHR 1, para 25; and De Cubber v Belgium [1984] ECHR 14, para 30. 198 Document of the Moscow Meeting of the Conference on the Human Dimension of the CSCE, Moscow 1991, para 19.2, page 113. See also, UN Basic Principles on the Independence of the Judiciary, adopted in 1985 by the UN General Assembly Resolutions 40/32 and 40/146. 199 OSCE Office for Democratic Institutions and Human Rights, “Kyiv Recommendations on Judicial Independence in Eastern Europe, South Caucasus and Central Asia”, Kyiv, 23–25 June 2010. 200 UN Human Rights Committee, CCPR General Comment 32 (2007), para 25; Ringeisen v Austria [1971] ECHR 2, para 95; and Le Compte, Van Leuven and De Meyere v Belgium [1981] ECHR 3, para 55. See also, UN Basic Principles on the Independence of the Judiciary, adopted in 1985 by the UN General Assembly Resolutions 40/32 and 40/146, para 4: “There shall not be any inappropriate or unwarranted interference with the judicial process”. 201 See, for example, Grieves v the United Kingdom [2003] ECHR 688, para 69.