v. Eritrea, the Commission adopted three assessment criteria: the complexity of the case, and the conduct of the applicant and of the relevant authorities of the Respondent State.27 112. Moreover, in the case of Pagnoulle (on behalf of Mazou) v. Cameroon, the Commission held that two (2) years of proceedings without any trial and without being given any reason for the delay constituted a violation of the right to be tried within a reasonable time.28 In the case of Centre for Free Speech v. Nigeria concerning a two-year period of detention without trial, the Commission laid emphasis on the need for cases involving pre-trial detention to be tried as expeditiously as possible.29 113. Regardless of the circumstances, the Commission is of the view that a period of seven (7) years of pre-trial detention without any final judgement cannot obviously be considered as a reasonable period. The same circumstances led to this conclusion in the case of Abubakar v. Ghana.30 114. In this case, at the time the matter was seized by the Commission, the Complainant had been in pre-trial detention for a period of close to four years (44 months) whereas the criminal law of the Respondent State provides for a maximum of 18 months, unless there are other charges against the Complainant. In total, it took a period of six (6) years of pre-trial detention at the time the Commission took a decision on admissibility and seven (7) years at the time of the present decision, without any final judgement being passed against the Complainant. Article 19 v. Eritrea op. cit. paras 97-100. See Pagnoule Communication 39/90 (2000) AHRLR 57 (ACHPR 1997). 29 Centre for Free Speech v. Nigeria Communication 206/97 (2000) AHRLR 250 (ACHPR 1999) paras 19-20. 30 Communication 103/93 (2000) AHRLR 124 (ACHPR 1996) paras 10-12. 27 28 33