97. In the case of Colozza v ltaly,11 the European Court of Human Rights held that the right to a hearing in one's presence is part of the right to a 'fair hearing' in Article 6(1) of the European Convention on Fundamental Rights and Freedoms (the European Convention). 12 The Court notes that Article 6 of the European Convention is similar to Article 7 of the Charter.1s 98. In a similar vein, the Inter-American Court of Human Rights has found violations of Article 8 of the American Convention on Human Rights which provides for the right to a fair trial, similar to the provisions of Article 7 of the Charter. Of note is the Case of Suarez-Rosero v Ecuador where the Inter-American Court of Human Rights affirmed the minimum guarantees to which every person is entitled under Article 8(2)(c), (d) and (e) of the American Convention on Human Rights, with full equality. 14 11 12 Application No. 9024/80 A 89 (1985) 7 European Human Rights Reports 516. In that case, the European Court of Human Rights stated that "Although this is net expressly mentioned in paragraph 1 of Article 6 (art. 6-1), the object and purpose of the Article taken as a whole show that a person "charged with a criminal offence" is entitled to take part in the hearing. Moreover, sub-paragraphs (c), (d) and (e) of paragraph 3 (art. 6-3-c, art. 6-3-d, art. 6-3-e) guarantee to "everyone charged with a criminal offence" the right "to defend himself in person", "to examine or have examined witnesses" and "to have the free assistance of an interpreter if he cannot understand or speak the language used in court", and it is difficult to see how he could exercise these rights without being present." 13 Application No. 9024/80 Colozza v Italy A 89 (1985) 7 European Human Rights Reports 516 paragraph 27. 14 Judgment of 12 November, 1997 (Merits) paragraph 82. These guarantees include "[a]dequate time and means for the preparation of his defense [t]he right of the accused to defend himself personally or to be assisted by legal counsel of his own choosing, and to communicate freely and privately with his counsel; [and] the inalienable right to be assisted by counsel provided by the state, paid or not as the domestic law provides, if the accused does not 38