Chapter ii  Rights of Access to Justice and Equality in the Administration of Justice 47 “The enjoyment of any right set forth by law shall be secured without discrimination on any ground…”158 In González v Spain, the author claimed that there was a violation of Article 14(1) of the ICCPR, together with Article 26 (equality and non-discrimination), by virtue of the fact that she was unable to appear before the Constitutional Court without being represented by a procurador (legal counsel accredited to the Constitutional Court). The author claimed that this resulted in an inequality before the law, since those with a law degree did not need to be represented, whereas those without a law degree were required to be represented by a procurador. The Human Rights Committee accepted the position of the Constitutional Court, i.e., that the requirement for representation reflected the need for a person with legal training to assume responsibility for proceedings in connection with appeals to that court. The Committee did not accept, on the evidence before it, that this failed to be based upon objective and reasonable criteria.159 2.3 Abbreviated or simplified proceedings The Human Rights Committee, in its General Comment on the right to a fair trial, refers to the equality before courts and tribunals as requiring that similar cases be dealt with in similar ways. If exceptional criminal procedures or specially constituted courts or tribunals apply in the determination of certain categories of cases, this distinction must be justified on objective and reasonable grounds.160 In its Concluding Observations to the fifth period report of the United Kingdom, for example, the Human Rights Committee gave consideration to the fact that some elements of criminal procedure differed between Northern Ireland and the remainder of the United Kingdom. In particular, under the so-called “Diplock court” system in Northern Ireland, persons charged with certain offences were subject to a different regime of criminal procedure, including the absence of a jury. This modified procedure was applicable unless the Attorney-General certified the contrary, although there was no need to give reasons for such certification. The Committee emphasized that the application of different criminal procedures requires objective and reasonable grounds to be provided by the appropriate prosecution authorities. It recommended that the United Kingdom ensure that, in every case where an individual was subjected to a “Diplock court”, there were objective and reasonable grounds justifying this.161 158 Protocol 12 of the ECHR, adopted on 4 November 2000. See also the following articles of the Universal Declaration of Human Rights (UDHR), adopted by the UN General Assembly under its resolution 217 (III) of 10 December 1948: article 1 (right to equality in dignity and rights); article 2 (enjoyment of rights without distinction); article 6 (recognition before the law); and article 7 (equality before the law). 159 González v Spain, HRC Communication 1005/2001, UN Doc CCPR/C/74/D/1005/2001 (2002), para 4.3. 160 UN Human Rights Committee, CCPR General Comment 32 (2007), para 14. 161 UN Human Rights Committee, Concluding Observations: the United Kingdom of Great Britain and Northern Ireland, UN Doc CCPR/CO/73/UK (2001), para 18.