complexity of the case, the conduct of the perpetrator and that of the competent authorities.” (See the European Court of Human Rights, cases of KEMMACHE v. FRANCE, judgment of 27 November 1991, Series A, No. 218, p. 20, § 50 (criminal); MARTINS MOREIRA v. PORTUGAL, judgment of 26 October1988, Series A, No. 143, p. 17, § 45 (civil)) 196. The African Commission follows in the same sense in the “Principles and Guidelines on the Right to a Fair Trial and Legal Assistance in Africa”, p.15 §5 - the African Court, in the case of ALEX THOMAS v. UNITED REPUBLIC OF TANZANIA, Application No. 005/2013 § 103 and 104 and the Inter-American Court in the cited case, SAUREZ-ROSERO v. ECUADOR, §72). 197. In terms of the complexity of the case, it should be taken into account that all aspects of the case are relevant to assess whether or not it is complex. Complexity may concern factual issues as well as legal issues. For example, consideration should be given to the nature of the facts to be established, the number of accused persons and witnesses, international elements, consolidation of cases and the intervention of other persons in the proceedings. (See Nuala Mole and Catharina Harby, The right to a fair trial, A guide to the implementation of Article 6 of the European Convention on Human Rights, p. 26) 198. With regard to the Applicant's conduct, it should be noted that if the Applicant caused a delay, this obviously weakens his claim. However, the Applicant cannot be penalised for having made use of the various procedures available to him to pursue his defence. An Applicant is not obliged to cooperate actively to expedite proceedings that may lead to his own conviction. However, if the Applicant has tried to speed up the process, this will be considered in his favour. (See European Court, in the case of YAGCI AND SARGIN v. TURKEY § 66) 38