conduct thorough investigations and evaluations to satisfy itself that there was no doubt about the conviction and sentence to be meted against the Applicant. *** 94. Article 7(1)(d) of the Charter provides that: Every individual shall have the right to have his cause heard. This comprises the right to be tried within a reasonable time …. 95. The Courts recalls its established jurisprudence as exemplified in Wilfred Onyango Nganyi and Others v. United Republic of Tanzania, that the right to be tried within a reasonable time is an important aspect of fair trial. There is no standard period that is considered as reasonable time for a court to dispose of the matter.44 The Court further held that the right to a fair trial also includes the principle that judicial proceedings should be finalised within a reasonable time.45 Delays caused by the lack of due diligence on the part of national authorities would amount to a violation of the right to be tried within a reasonable time. 96. In determining the right to be tried within a reasonable time, the Court has adopted a case-by-case approach whereby it considered, among others, factors such as the complexity of the case, the conduct of the parties, and that of the judicial authorities who must exercise due diligence especially where the Applicant faces severe penalties.46 97. With regard to complexity of the case, the Court has considered factors such as the number of witnesses who testified, availability of evidence, the level 44 Wilfred Onyango Nganyi and Others v. United Republic of Tanzania (merits) (18 March 2016), 1 AfCLR 507, § 127; and Benedicto Daniel Mallya v. United Republic of Tanzania (merits and reparations) (26 September 2019) 3 AfCLR 482, § 48. 45 Cheusi v. Tanzania (judgment), supra, § 116. 46 Marthine Christian Msuguri v. United Republic of Tanzania, ACtHPR, Application No. 052/2016, Judgment of 1 December 2022 (merits and reparations), § 83; Cheusi v. Tanzania (judgment), supra, § 117; Guehi v. Tanzania (merits and reparations), supra, § 501. 26

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