20 parties before it are accorded the same procedural rights and operate under the same procedural conditions in court. According to the Prosecution, the lack of cooperation by the authorities in the Republika Srpska could not imperil the equality of arms enjoyed by the Defence at trial because the Trial Chamber had no control over the actions or the lack thereof of those authorities. 46. The Defence contends that the minimum guarantee in Article 21(4)(b) of the Statute to adequate time and facilities for the preparation of defence at trial forms part of the principle of equality of arms, implicit in Article 20(1). It argues that, since the authorities in the Republika Srpska failed to cooperate with the Defence, the Appellant did not have adequate facilities for the preparation of his defence, thereby prejudicing his enjoyment of equality of arms. 47. The Appeals Chamber accepts the argument of the Defence that, on this point, the relationship between Article 20(1) and Article 21(4)(b) is of the general to the particular. It also agrees that, as a minimum, a fair trial must entitle the accused to adequate time and facilities for his defence. 48. In deciding on the scope of application of the principle of equality of arms, account must be taken first of the international case law. In Kaufman v. Belgium, 79 a civil case, the Eur. Commission H. R. found that equality of arms means that each party must have a reasonable opportunity to defend its interests “under conditions which do not place him at a substantial disadvantage vis-à-vis his opponent”. 80 In Dombo Beheer B.V. v. The Netherlands, 81 another civil proceeding, the Eur. Court H. R. adopted the view expressed by the Eur. Commission H. R. on equality of arms, holding that “as regards litigation involving opposing private interests, ‘equality of arms’ implies that each party must be afforded a reasonable opportunity to present his case – including his evidence – under conditions that do not place him at a substantial disadvantage vis-à-vis his opponent”. 82 The Court decided in a criminal proceeding, Delcourt v. Belgium,83 that the principle entitled both parties to full equality of treatment, maintaining that the conditions of trial must not “put the accused 79 Kaufman v. Belgium, 50 DR 98. Ibid., p. 115. 81 Dombo Beheer B.V. v. The Netherlands, Eur. Court H. R., judgement of 27 October 1993, Series A, no. 274. 82 Ibid., para. 40. 83 Delcourt v. Belgium, Eur. Court H. R., judgement of 17 January 1970, Series A, no. 11. 80 Case No.: -94-1-A 15 July 1999