Chapter vi  Equality of Arms and Rights to a Fair Hearing 129 budgetary appropriations for the administration of criminal justice will not justify unreasonable delays in the adjudication of criminal cases.545 In Teesdale v Trinidad and Tobago, the Human Rights Committee considered a delay of 16 months in the murder trial of the accused to be unreasonable.546 The trial transcript in that case showed that all evidence for the case of the prosecution had been gathered by 1 June 1988 and no further investigations were carried out, whereas the trial did not begin until 6 October 1989. In Boodoo v Trinidad and Tobago, the Committee concluded that a period of 33 months between arrest and trial on a charge of larceny (theft) constituted undue delay and could not be deemed compatible with the provisions of Article 9(3).547 Likewise, the arrest, in September 1985, and continued detention of the author in Sahadeo v Guyana until he was first convicted of murder and sentenced to death in November 1989 (four years and two months after his arrest) was found to be in violation of Article 9(3) of the Covenant.548 Even taking into account the number of accused and witnesses involved in the trial, the European Court of Human Rights found a delay of eight years and two months as unreasonable for the purpose of Article 6(1) of the ECHR.549 In contrast, a period of 11 months between arrest and hearing of charges of importation and trafficking of heroin was not found to constitute a violation of Article 14(3)(c) of the ICCPR in Hussain v Mauritius.550 6.4.3 The right to bail pending the disposal of criminal proceedings The right to an expeditious trial is all the more important in the context of one’s deprivation of liberty. Article 9(3) of the ICCPR and Article 5(3) of the ECHR refer to the right of everyone arrested or detained to “trial within a reasonable time or to release” pending trial. If an accused is denied bail and thereby held in custody during the course of a criminal proceeding, the person must be tried as expeditiously as possible.551 In Sextus v Trinidad and Tobago, where the applicant was arrested on the day of the alleged offence, charged with murder, and held until trial, and where the factual evidence was considered by the Human Rights Committee as straightforward and requiring little police investigation, the Committee concluded that a 22-month delay until trial amounted to a violation of Article 9(3) and Article 14(3)(c) of the ICCPR.552 In Barroso v Panama, the Committee considered that a delay of 545 Zimmerman and Steiner v Switzerland [1983] ECHR 9, para 29; Vernillo v France [1991] ECHR 23; and Fillastre and Others v Bolivia, HRC Communication 336/1988, UN Doc CCPR/C/43/D/336/1988 (1991), para 6.5. 546 Teesdale v Trinidad and Tobago, HRC Communication 677/1996, UN Doc CCPR/C/74/D/677/1996 (2002), para 9.3. 547 Boodoo v Trinidad and Tobago, HRC Communication 721/1996, UN Doc CCPR/C/74/D/721/1996 (2002), para 6.2. 548 Sahadeo v Guyana, HRC Communication 728/1996, UN Doc CCPR/C/73/D/728/1996 (2001), para 9.2. 549 Angelucci v Italy [1991] ECHR 6, para 15 (under the heading “As to the Law”). 550 Hussain v Mauritius, HRC Communication 980/2001, UN Doc CCPR/C/77/D/980/2001 (2002), para 6.5. 551 UN Human Rights Committee, CCPR General Comment 32 (2007), para 35; and Jablonski v Poland [2000] ECHR 685, para 102. 552 Sextus v Trinidad and Tobago, HRC Communication 818/1998, UN Doc CCPR/C/72/D/818/1998 (2001), para 7.2;