rights and how to avail himself of such rights.” However, the UNHCR document on ‘Detention of Refugees and Asylum-Seekers’ does not require legal counsel, but merely that “refugees and asylum-seekers who are detained be provided with the opportunity to contact the Office of the United Nations High Commissioner for Refugees or, in the absence of such office, available national refugee assistance agencies.” 217. The Commission finds that not being able to contact their families is not a violation of the procedural rights under Article 6, as it does not affect their liberty or security. The remaining arguments of the Complainants is that the Victims were not given specific reasons for their arrest nor were they given access to lawyers or a court to determine the lawfulness of their detention. In Abdolkhani and Karimnia v. Turkey, a case of the European Court of Human Rights, the court held that because the reasons for their arrest was not communicated to them, the right to review was effectively denied, and found a violation under Article 5 of the European Convention on Human Rights. This clearly shows that the right to reasons for the arrest is not an independent right, rather it is related to the right to review, and is only a violation if it results in the denial of effective review. As noted above, in the case of detention of asylum-seekers and refugees, international standards do not require access to a lawyer or a court for purposes of review, only that they be granted access to UNHCR, which was in fact done in the present case. Commission thus finds that being granted access to UNHCR is sufficient and that they did not in addition have to be provided with legal counsel, since the UNHCR could have sufficiently supported them in any administrative review processes. The Commission thus finds that there was no violation of Article 6. Analysis of Article 11 218. The African Charter provides in Article 11 that “[e]very individual shall have the right to assemble freely with others.” It further contains an internal limitation, namely that “the exercise of this right shall be subject only to necessary restrictions provided for by law in particular those enacted in the interest of national security, the safety, health, ethics and rights and freedoms of others.” 60

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