121. International criminal jurisprudence contains cases of the equality of arms in some major decisions. In the case of The Prosecutor v. Clément Kayishema and Obed Ruzindana, the International Criminal Tribunal for Rwanda held that “the right of an accused to a fair trial implies the principle of equality of arms between the Prosecution and the defence”. The Tribunal went on to recall the provisions of its Statute under which equality of arms includes, among others, “the right to have adequate time and facilities to prepare his or her defence”. 29 Moreover, in order to determine the scope of equality of arms, the Tribunal drew from the decision handed down in the case of The Prosecutor v. Tadić in which the International Criminal Tribunal for the Former Yugoslavia held that “equality of arms obligates a judicial body to ensure that neither party is put at a disadvantage when presenting its case”.30 122. The European Court of Human Rights case law follows the same path in the case of Neumeister v. Austria, where it refers to the equality of arms as part of a fair trial before an independent and impartial tribunal.31 Reiterating this principle the other way round, the European Court held in a subsequent decision, Delcourt v. Belgium, that “a trial would not be fair if it took place in such conditions as to put the accused unfairly at a disadvantage.”32 123. As for the scope of application of the equality of arms, the European Court takes the position that equality of arms applies to all proceedings involving rights or civil obligations, even if the content of the principle does not have the same implication in criminal and civil matters. 33 Although the European Court thus gives this principle a general scope, it did not intend to make it absolute. States are not required to establish strict procedural equality between the parties, but rather to ensure that the parties benefit from a reasonably egalitarian situation. It is also in the administration of evidence that the European Court assesses whether or not there is equality of arms, in terms of both the possibility of witnesses being heard34 or on the judge's power to order or refuse an investigative measure. 35 124. The Human Rights Committee of the United Nations, for its part, takes equality of arms beyond the confines established by the European Court in the case of Robinson v. Jamaica to find out, beyond legal weapons, if indeed the Judgement The Prosecutor v. Clément Kayishema and Obed Ruzindana (Appeal) para 67. Highlighted by the Commission. 30 Judgement The Prosecutor v. Tadić (Appeal) para 48. 31 Neumeister v. Austria (27 June 1968) Series A No. 8 para 24. 32 Delcourt v. Belgium (17 January 1970) Series A No. 1 para 25. 33 See Dombo Beheer B.V. v. The Netherlands (27 October 1993). 34 Dombo Beheer v. Netherlands (27 October 1993). 35 H. v. France (24 October 1989). 29 24