72. Firstly, regarding the nature and complexity of the case, the Court has in its previous judgments adopted a case-by-case approach to assessing whether a matter is complex. The Court among other factors considered the number of witnesses who testified, availability of evidence, the scope of investigations, and whether specialised evidence such as DNA samples were required.27 73. The Court notes that in the present Application, the Respondent State’s investigation into the alleged crime took nearly four (4) years to complete. Meanwhile, the case involved an allegation of murder and no complex or advanced evidence was adduced. Furthermore, the Respondent State only presented oral testimony and five (5) prosecution exhibits which were all available within months of the arrest. As such, there is no basis for the case to be considered as a complex one to merit such a period of time for investigation and the delay being complained of can, therefore, not be attributed to the nature and complexity of the case. 74. Secondly, regarding the conduct of the Parties, the Court observes that when the Applicant was arrested, he submitted to the authorities and there is no suggestion that he delayed the proceedings. There is no indication from the record that the Applicant acted in any manner or made any request that contributed to the delay. 75. Thirdly, regarding exercise of due diligence by the authorities of the Respondent State, the Court notes that, pursuant to Section 32(1) of the CPA of the Respondent State, an accused must be brought before a court within 24 hours after he is taken into custody or as soon as practicable especially when the offence is punishable with death.28 Further, Section 27 Cheusi v. Tanzania, ibid., § 117; Guehi, ibid., § 112; Nganyi and Others v. Tanzania (merits), § 115. Section 32(1) – Where any person has been taken into custody without a warrant for an offence other than an offence punishable with death, the officer in charge of the police station to which he is brought may, in any case, and shall if it does not appear practicable to bring him before an appropriate court within twenty four hours after he was so taken into custody, inquire into the case and, unless the offence appears to that officer to be of a serious nature, release the person on his executing a bond with or without sureties, for a reasonable amount to appear before a court at a time and place to be named in the bond; but where he is retained in custody, he shall be brought before a court as soon as practicable. 28 20