130 Legal Digest of International Fair Trial Rights over three and a half years between indictment and trial could not be justified solely by the complex factual situation and protracted investigations. In cases involving serious charges, such as homicide or murder, and where the accused is denied bail, the Committee stated that the accused must be tried in as expeditious a manner as possible.553 6.4.4 The right to a hearing within a reasonable time in civil proceedings The right to a hearing within a reasonable time is treated by both the Human Rights Committee and the European Court of Human Rights as being applicable to both criminal and non-criminal proceedings, although it is only the ECHR that refers explicitly to this principle within the context of both criminal and civil proceedings.554 According to the Human Rights Committee, delays in civil proceedings cannot be justified by the complexity of the case or the behaviour of the parties (See also 6.4.1).555 The right to a hearing within a reasonable time in civil proceedings relates to the time from which the proceedings are instituted 556 to when the determination of the court becomes final and the judgment has been executed.557 In Jankovic v Croatia, a case concerning, inter alia, disturbance of possession, the European Court of Human Rights reiterated that the execution (enforcement) of a judgment must be regarded as an integral part of the “hearing” for the purposes assessing the reasonableness of the length of the proceedings.558 The Human Rights Committee has treated the prompt disposal of civil proceedings as a requirement arising from the general provisions of Article 14 (1) of the ICCPR. Following his illegal detention in 1979, for example, the author in Mukunto v Zambia filed a complaint for compensation before the Supreme Court in 1982 and 1985. By 1999, when the Human Rights Committee considered his complaint under Article 14(1), his claim for compensation had still not been adjudicated upon. Neither of the author’s claims under Article 14 were refuted by Zambia, which, instead, put before the Committee reasons for the non-payment of compensation, including economic difficulties to provide adequate conditions to all detained persons. The Committee did not consider this to be a relevant response to the claim of violation of Article 14(1) and found that the author’s rights had not been respected.559 A similar approach was taken by the Committee concerning delays in the disposal of slander proceedings in Paraga v Croatia, a five-year delay in criminal proceedings in Muñoz v Spain, a seven-year delay in the disposal of administrative review proceedings in 553 Barroso v Panama, HRC Communication 473/1991, UN Doc CCPR/C/54/D/473/1991 (1995) para 8.5. 554 UN Human Rights Committee, CCPR General Comment 32 (2007), para 27. See, for example, Hermoza v Peru, HRC Communication 203/1986, CCPR/C/34/D/203/1986 (1988), para 11.3, and Fei v Colombia, HRC Communication 514/1992, UN Doc CCPR/C/53/D/514/1992 (1995), para 8.4. 555 UN Human Rights Committee, CCPR General Comment 32 (2007), para 27. 556 In certain circumstances, time may begin to run even before the issue of the writ commencing proceedings before the court, see Golder v the United Kingdom [1975] ECHR 1, para 32 in fine. 557 Scopelliti v Italy [1993] ECHR 55, para 18. 558 Jankovic v Croatia [2009] ECHR 401, para 68; Hornsby v Greece [1997] ECHR 15, para 40; Plazonić v Croatia [2008] ECHR 198, para 47. 559 Mukunto v Zambia, HRC Communication 768/1997, UN Doc CCPR/C/66/D/768/1997 (1999), para 6.4.