103. The African Commission has found that the right to be tried by an impartial tribunal within a reasonable time is one of the cardinal principles of the right to a fair trial5 and that the undue prolongation of the case at the appellate level is contrary to the letter and spirit of Article 7(1)(d) of the African Charter. 16 104. Similarly, the Inter-American Court of Human Rights has elaborated on the principle of reasonable time, as set forth in Article 8(1) of the American Convention on Human Rights, which is similar to Article 7(1)(d) of the Charter. 17 In doing so, the Inter-American Court has adopted the approach of the European Court of Human Rights in this regard, in respect of which the latter Court has laid ou three elements which should be taken into account to establish the fairness of the time incurred in judicial proceedings. These are: a) the complexity of the matter, b) the procedural activities carried out by the interested party, and c) the conduct of judicial authoritieS.18 15 Communication 301/05 Haregewoin Gebre-Se/laise & Institute for Human Rights and Development in Africa (on behalf of former Dergue officials) v Ethiopia decision of 7 November 2011 paragraph 215.. 16 Communication 199/97 Odjouoriby Cossi Paul v Benin (17th Activity Report 2003- 2004) paragraph 28. 17 Case of Suarez-Rosero v Ecuador Judgment of 12 November 1997 (Merits) paragraph 72. See also Case of Ximenes-Lopes v. Brazil, 4 July 2006, IACHR Series C No. 149, paragraph 196; and Case of the ltuango Massacres v. Colombia, 1 July 2006, IACHR Series C No. 148 paragraph 289, Case of Yl/aconza Ramirez de Balde6n and Others (on behalf of Balde6n Garcia) v Peru, IACHR Judgment of 6 April 2006, paragraph 15. 18 See ECHR Ruiz Mateos v. Spain Judgment of 23 June 1993, Series A No. 262, paragraph 30.