be released. (See paragraph 2 (c) of ACHPR/Res. 4(XI) 92: Resolution on the Right to Appeal and Fair Trial (1992)). 192. In order to give effect to the notion of “reasonable time”, this Court in the case of AMOUZOU HENRI ET 5 AUTRES v. REPUBLIC DE CÔTE D' IVOIRE, Judgment no. ECW/CCJ/JUD/04/09, LRCCJ (2009) § 93 stressed that international courts competent in the application of international human rights instruments consider that the “reasonable time” for holding the trial of detainees should be determined according to: the merits of each case, the specificity of the procedure, the degree of complexity and nature of the offence, the difficulty in the investigation and the number of persons involved. 193. It further reiterated in the cited case MR. IBRAHIM SORY TOURÉ AND MRISSIAGA BANGOURA v. THE REPUBLIC OF GUINEA, §108, that what is reasonable must be assessed in the circumstances of each case, considering primarily the complexity of the case, the conduct of the accused and the manner in which the matter was handled by the administrative and judicial authorities. 194. In the same vein, see also Human Rights Committee, Communication No. 818/1998, SEXTUS v. TRINIDAD AND TOBAGO, §7.2,in relation to a 22-month delay between the indictment of the accused of a crime with death penalty and the commencement of the trial without specific circumstances justifying the delay; Communication No. 938/2000, SIEWPERSAUD, SUKHRAM, AND PERSAUD v. TRINIDAD AND TOBAGO § 6.2 in relation to the total length of criminal proceedings of almost five years, in the absence of any explanation from the State party justifying the delay. 195. On the question of the reasonableness of the length of proceedings, whether civil or criminal, the European Court, equally and consistently holds that: “the particularities of the case must be taken into consideration, based on the criteria determined in the Court's precedents, in particular the 37