  Obligations to perform military or civic service. Minor punitive measures imposed on civil servants, armed forces and prisoners; except where the result is dismissal from employment616 or deprivation of liberty.617 Both will have the protection of Article 14(1) ICCPR. 61. Although the right does not apply to extradition, expulsion and deportation procedures,618 Article 13 of the ICCPR in conjunction with Article 14 requires that asylum seekers and refugees have a right of access to courts and tribunals.619 However, there are several points to note: 62. If an alien is lawfully in the territory of a state, this does not invoke the protection of Article 14 ICCPR,620 although it will invoke Article 13. Here Article 13 will require that the expulsion must be:  Be made in accordance with the law;  The individual must have the opportunity to give reasons against their expulsion;  They must have the case reviewed by, and be represented in this context, a competent authority or persons designated as such. Such protections do not apply if there are national security concerns.  Such guarantees also need to be interpreted in light of Article 14 and fair trial provisions.621 63. Secondly, for aliens unlawfully in the territory, neither Articles 13 nor 14 apply, unless the lawfulness is in dispute.622 64. Lastly, for all other proceedings, whether they be civil or criminal, where an alien is a party, Articles 13 and 14 will apply. I. The right to be informed promptly in a language which he understand and in detail, of the nature and cause of the accusation against him623 65. An individual needs to be informed, in a manner which they understand, of the nature of the charges against them. This enables them to begin preparing their defence.624 616 Human Rights Committee, Communication 441/1990, Casanovas v France, 19 July 1994, para 5.2; Communication 2015/2001, Perterer v Austria, 20 July 2004 para 9.2. 617 Engel v Others v The Netherlands, [1976] ECHR 3, para 81. 618 Human Rights Committee General Comment No.32, CCPR/C/GC/32 (2007), para 17. 619 Ibid. 620 Human Rights Committee General Comment No.32, CCPR/C/GC/32 (2007), para 62. Kaur v Canada, Communication 1455/2006, UN Doc.CCPR/C/94/D/1455/2006 (2008), para 7.5; Chadzjian v The Netherlands, Communication 1494/2006, UN Doc.CCPR/C/93/D/1494/2006 (2008), para 8.4. 621 Human Rights Committee General Comment No.32, CCPR/C/GC/32 (2007), para 62; Communication 961/2000, UN Doc.CCPR/C/81/D/961/2000 (2004), para 6.4. 622 Human Rights Committee, General Comment 15, (1986), para 9. 623 Article 14(3)(a) ICCPR; Article 6(3)(a), ECHR 624 In Brozicek v Italy the applicant was German and therefore he needed the charge properly explained to him in a language which he could understand. 110

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