deprived of their liberty are brought promptly before a judicial authority"84 . The same principle was held in Abdel J:ladi & Others v Republic of Sudan and in Huri-Laws v. Nigeria, where the Commission found that the "refusal and/ or negligence" of the respondent state to bring the applicant "promptly before a judge or other judicial officer for trial" constituted a violation of Article 7 (1) (d) of the African Charter. 177. While courts and international human rights bodies have determined the meaning of 'promptness' based on the facts and circumstances of the individual case, they have set clear upper time limits. General Comment No. 8 of the UN Human Rights Committee on Article 9 of the International Covenant on Civil and Political Rights sets out that, "[m]ore precise time-limits are fixed by law in most States parties and, in the view of the Committee, delays must not exceed a few days" 85 . The Commission in the same spirit has held in Annette Pagnoulle v. Cameroon 86 , that two (2) years without any hearing or projected trial date, constitutes a violation of article 7 (1) (d) of the African Charter. 178.Additionally, the Commission notes that the Constitution of Uganda87 establishes that" a person arrested or de,tained ... upon reasonable suspicion of his or her having committed or being about to commit a criminal offence under the laws of Uganda, shall, if not earlier released, be brought to court as soon as possible but in any case, not later than 48 hours from the .time of his or her arrest"88 . 179. The Commission is therefore of the view that, the length of detention of the Victim of 23 -months in custody without charges being filed and not brought before a judicial authority89, not only constitutes an undue delay in contravention to the guarantees laid by the Commission and international standards, but also exceeds the prescribed duration underlined in the Constih,ltion of Uganda?0• See M2 (a)(b) and 3 (A) of the Principles and Guidelines on Fair Trial & Article 25, 26 & 27 of the Robben Island Guidelines 85 UN Human Rights Committee, "General Comment No.8 Right to Liberty and Security of Persons (30 June 1982) at para 2 86 Communication 39/90, Annette Pagnoulle (on behalf of Abdoulaye Mezou) v Cameroon 84