Chapter vi  Equality of Arms and Rights to a Fair Hearing 115 6.3 Adequate preparation Article 14 of the ICCPR “(1) In the determination of any criminal charge against him, or of his rights and obligations in a suit at law, everyone shall be entitled to a fair… hearing… “(3) In the determination of any criminal charge against him, everyone shall be entitled to the following minimum guarantees, in full equality: “(a) To be informed promptly and in detail in a language which he understands of the nature and cause of the charge against him; “(b) To have adequate time and facilities for the preparation of his defence and to communicate with counsel of his own choosing;” Article 6 of the ECHR “(1) In the determination of his civil rights and obligations or of any criminal charge against him, everyone is entitled to a fair… hearing… “(3) Everyone charged with a criminal offence has the following minimum rights: “(a) to be informed promptly, in a language which he understands and in detail, of the nature and cause of the accusation against him; “(b) to have adequate time and facilities for the preparation of his defence;” The right to have adequate time and facilities for the preparation of one’s case has been expressly recognized by the Human Rights Committee as an important element of the guarantee of a fair trial and an emanation of the principle of equality of arms.461 The rights associated with the preparation of one’s case involve a range of issues. Some rights are expressed as minimum guarantees in criminal proceedings (see Article 14(3)(a) and (b) of the ICCPR and Article 6(3)(a) and (b) of the ECHR). Often, however, there are parallel rights applicable to non-criminal proceedings, based either on the principle of equality of arms (See also 6.1) or on the overall need to ensure that proceedings are “fair” (as required by Article 14(1) of the ICCPR and Article 6(1) of the ECHR). 461 UN Human Rights Committee, CCPR General Comment 32 (2007), para 32; Smith v Jamaica, HRC Communication 282/1988, UN Doc CCPR/C/47/D/282/1988 (1993), para 10.4.