128 Legal Digest of International Fair Trial Rights • the need for law enforcement authorities to obtain mutual legal assistance;536 • any detrimental effect caused by the delay upon the individual’s legal position;537 • the availability of remedies to accelerate the proceedings, and whether these were called upon;538 • the outcome of any appellate proceedings;539 • the link the case has with any other proceeding and whether the interests of justice call for stages in the two proceedings to be co-ordinated or to await steps or decisions to be taken in the other proceedings;540 and • the repercussions the case may have on the future application of national law.541 The right to a timely hearing must also be balanced against the right to adequate time and facilities to prepare one’s case (See also 6.3.4 and 6.3.5), in which case there might be an entitlement to receive an adjournment of proceedings. 6.4.2 The right to be tried without undue delay in criminal proceedings The right, in criminal proceedings, to be tried without undue delay relates to the time from when a person is charged or arrested (which sometimes, but not always, occur at the same time) until judgment is rendered (See also 9.3) and any applicable appeals or reviews are completed (See also 10.1.1).542 The European Court of Human Rights considers the period to be taken into account in the assessment of the length of the proceedings as starting from an official notification given to an individual by the competent authority of an allegation that s/he has committed a criminal offence or from some other act that carries the implication of such an allegation and that, likewise, substantially affects the situation of the suspect.543 In cases involving serious charges, such as homicide or murder, and where the accused is denied bail by the court (See also 6.4.3), the Human Rights Committee has repeatedly said that an accused must be tried in as expeditious a manner as possible.544 A lack of adequate 536 Manzoni v Italy [1991] ECHR 15, para 18 (under the heading “As to the Law”). 537 Deisl v Austria, HRC Communication 1060/2002, UN Doc CCPR/C/81/D/1060/2002 (2004), paras 11.2–11.6. 538 Deisl v Austria, HRC Communication 1060/2002, UN Doc CCPR/C/81/D/1060/2002 (2004), paras 11.2–11.6. 539 Deisl v Austria, HRC Communication 1060/2002, UN Doc CCPR/C/81/D/1060/2002 (2004), paras 11.2–11.6. 540 Boddaert v Belgium [1992] ECHR 62, para 39. 541 Katte Klitsche de la Grange v Italy [1994] ECHR 34, para 62. 542 UN Human Rights Committee, CCPR General Comment 32 (2007), para 35; Deweer v Belgium [1980] ECHR 1, para 42; Taright, Touadi, Remli and Yousfi v Algeria, HRC Communication 1085/2002, UN Doc CCPR/C/86/D/1085/2002 (2006), para 8.5; Rouse v the Philippines, HRC Communication 1089/2002, UN Doc CCPR/C/84/D/1089/2002 (2005), para 7.4; and Sobhraj v Nepal, HRC Communication 1870/2009, UN Doc CCPR/C/99/D/1870/2009 (2010), para 7.4. 543 Kangasluoma v Finland [2004] ECHR 29, para 26; see also Corigliano v Italy [1982] ECHR 10, para 34; Eckle v Germany [1982] ECHR 4, para 73. 544 See, for example, Barroso v Panama, HRC Communication 473/1991, UN Doc CCPR/C/54/D/473/1991 (1995), para 8.5; and Francis v Trinidad and Tobago, HRC Communication 899/1999, UN Doc CCPR/ C/75/D/899/1999 (2002), para 5.4.