Chapter i  Fair Trial Standards: Scope of Application 21 during the course of criminal and civil proceedings.16 Fair trial standards are relevant to the exercise of the right to an effective remedy (Article 2(3) of the ICCPR and Article 13 of the ECHR).17 The imposition of a sentence of death upon conclusion of a trial (See also 8.3.6), during which fair trial guarantees have not been scrupulously respected, constitutes a violation of the right to life (Article 6 of the ICCPR and Article 2 of the ECHR).18 Compelling a person to confess guilt through ill-treatment or torture violates both the minimum fair trial guarantees prohibiting such compulsion (See also 5.2.6) and the non-derogable prohibition against torture and inhuman, cruel or degrading treatment (Article 7 of the ICCPR and Article 3 of the ECHR).19 Criminal defamation charges against journalists may, if kept pending for several years, amount to a violation of the right to trial without undue delay (See also 6.4), as well as having a chilling effect on the media which would adversely affect the right to freedom of expression (Article 19 of the ICCPR and Article 10 of the ECHR).20 Unreasonable delays may also prevent an accused from leaving the country and may thereby violate the right of every person to leave one’s own country (Article 12 of the ICCPR and Article 2(2) of Protocol 4 to the ECHR) while proceedings are pending.21 The dismissal of judges might not only concern the independence of the judiciary (See also 3.3.1) but may, depending on the circumstances, also be in violation of the right to have access to public service on general terms of equality (Article 25(c) of the ICCPR).22 Any distinctions regarding access to courts and tribunals (See also 2.1.2) based on the race, colour, sex, language, religion, political or other opinion, national or social origin, property, birth or other status will not only violate Article 14(1) of the ICCPR and Article 6(1) of the ECHR but will also amount to discrimination (Article 26 of the ICCPR and Article 14 of the ECHR).23 It should also be recalled that there is sometimes the need for fair trial guarantees to be limited when in conflict with other rights. This may occur, for example, in the context of restricting the access of the public to a hearing in order to protect the private lives of one or more of the parties (See also 4.1.5), or restricting the requirement of a public pronouncement of judgment where the interest of juvenile persons requires (See also 9.1.2). 16 UN Human Rights Committee, CCPR General Comment 32 (2007), para 58. 17 UN Human Rights Committee, CCPR General Comment 32 (2007), para 58; Czernin v the Czech Republic, HRC Communication 823/1998, UN Doc CCPR/C/83/D/823/1998 (2005), para 7.5; and Singarasa v Sri Lanka, HRC Communication 1033/2001, UN Doc CCPR/C/81/D/1033/2001 (2004), para 7.4. 18 UN Human Rights Committee, CCPR General Comment 32 (2007), para 59. 19 UN Human Rights Committee, CCPR General Comment 32 (2007), para 60. 20 UN Human Rights Committee, CCPR General Comment 32 (2007), para 63; and Kankanamge v Sri Lanka, HRC Communication 909/2000, UN Doc CCPR/C/81/D/909/2000 (2004), para 9.4. 21 UN Human Rights Committee, CCPR General Comment 32 (2007), para 63; and González del Rio v Peru, HRC Communication 263/1987, UN Doc CCPR/C/46/D/263/1987 (1992), paras 5.2–5.3. 22 UN Human Rights Committee, CCPR General Comment 32 (2007), para 64; Pastukhov v Belarus, HRC Communication 814/1998, UN Doc CCPR/C/78/D/814/1998 (2003), para 7.3; and Mundyo Busyo et al. v  Democratic Republic of Congo, HRC Communication 933/2000, UN Doc CCPR/C/78/D/933/2000 (2003), para 5.2. 23 UN Human Rights Committee, CCPR General Comment 32 (2007), para 9; UN Human Rights Committee, CCPR General Comment 18 (1989), para 7; and Ato del Avellanal v Peru, HRC Communication 202/1986, UN Doc CCPR/C/34/D/202/1986 (1988), para 10.2.