170.In general, the Commission has considered arbitrary detention, to mean a prolonged detention without trial. This position was held in Ouko v Kenya 75 , where the Complainant was detained for ten (10) months without trial. The same position was held in Free Legal Assistance Group and Others v. Zaire 76 , where the Commission held that a detention for an indefinite period of time was in violation of Article 6 of the African Charter. Furthermore, the UN Human Rights Committee has also held a similar position in Chambala v. Zambia 77, where it considered as arbitrary, a detention for a period of twenty-two (22) months without any grounds of detention. 171.Jn Constitutional Rights Project and Civil Liberities Organisation v. Nigeria 78, the Commission held that where individuals have been detained without charges being brought against them, constitutes an arbitrary deprivation of their liberty and thus a violation of Article 6 of the African Charter. The European Court of Human Rights has .also considered that the unacknowledged detention of an individual c;onstitutes a total negation of the fundamental guarantees enshrined in Article 5 of the Convention and an extremely serious violation of this provision 79 . Moreover, failure to record information such as the date and time 9f arrest, · the place of detention and the reasons for detention must .be deemed incompatible, inter alia, with the very purpose of Article 5 of the Convention80, as well as with the requirement that detention be lawful within the meaning of the Convention81 . 172.In line with the above reasoning, it is the Commission's view that arresting the Victim without giving him any reasons for his arrest and detaining him for a period .of 23 months without charge, constitutes arbitrary arrest and detention in conh·avention to the above-mentioned standards and principles laid down by the Commission, and thus, in violation of Article 6 of the African Charter. Alleged Violation of Article 7

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