and that the accused have access to trained and independent lawyers. Furthermore, the Principles explicitly recognise the right to habeas corpus,596 the right to be detained in a place recognised by law, the right of women detainees to special protection, and the need for independent inspections of places of detention to ensure the strict observance of all relevant standards. The Commission has explicitly taken these principles into account in subsequent decisions.597 Thus, the African system provides in great detail for a comprehensive system of procedural guarantees. However, it should be noted that the Commission does on occasion interpret these restrictively. In Purohit and Moore v The Gambia, for example, the Commission found that the inability of persons institutionalised on mental health grounds to appeal their detention, while falling short of international standards, did not violate the provisions of Article 6 of This right, along with a number of the other provisions of the Principles and Guidelines, had previously been affirmed by the Commission. See, for example, Constitutional Rights Project and Civil Liberties Organisation v Nigeria (1999), op. cit., §20–34. 597 See, for example, Zegveld and Ephrem v Eritrea, AfrCommHPR, Communication No. 250/2002, 34th session, 6–20 November 2003, §56 598 The Robben Island Guidelines, op. cit., §20(a). 599 Ibid. §20(b). 600 Ibid. §20(c). 601 Ibid. §28. 602 Ibid. §30. 603 Ibid. §40. 604 Ibid. §41. 605 AfrCommHPR, Res.61(XXXII)02: Resolution on Guidelines and Measures for the Prohibition and Prevention of Torture, Cruel, Inhuman or Degrading Treatment or Punishment in Africa (2002), §5. 4 The AFrican Regional System The Principles are complemented by the Robben Island Guidelines, which provide a number of procedural and other safeguards, in particular for persons deprived of their liberty. These include the right to inform a relative of detention,598 the right to an independent medical examination,599 the right of access to a lawyer,600 and the keeping of comprehensive records of interrogations601 and deprivation of liberty.602 Furthermore, the guidelines provide that States should establish independent complaint mechanisms for persons deprived of their liberty,603 and establish, support and strengthen independent national institutions with the mandate to conduct visits to all places of detention.604 While these guidelines are not strictly binding on States in the manner of the ACHPR, they do aid interpretation of that instrument, and the African Commission encourages States to include measures taken to implement the Guidelines in their periodic reports.605 596 135