47. The Complainants submit that the interpretation of the word ‘arbitrarily’ as being synonymous with the absence of fair trial guarantees is unneccesary since Article 7 of the African Charter has already provided for the same and hence submit that the S v. Mkwanyane & Anor approach should be adopted. The Complainants also highlight a decision of the Hungarian Constitutional Court, where it was held that the death penalty violated Article 54 of the Hungarian Constitution, in which no limitation clause was provided.11 48. The Complainants submit that the application of the death penalty, in general and in Botswana in particular, is inherently arbitrary and unequal because it is per se dependent on the discretion of the judge with other antecedent problems such as underfunded or non-existent legal aid and the reliance on junior lawyers for pro deo representation in capital cases. Under these circumstances, the imposition of the death penalty cannot escape the fact that it is not unfair or unequal. 49. The Complainants submit that there exists an unambiguous protection of the right to life under the African Charter and that any intention to limit this right through the death penalty would have been expressly stated as is the case under Article 6(2) of the International Covenant on Civil and Political Rights (ICCPR). That the Death Penalty as Imposed in the Republic of Botswana is Arbitrary 50. The Complainants submit that should the Commission hold that the prohibition of the arbitrary deprivation of life in Article 4 of the African Charter permits the imposition of the death penalty, the clemency procedure is arbitrary since it is a discretionary power of the Executive exercised by the President which is not subject to judicial review process. 51. The Complainants also submit that the death penalty is arbitrary in Botswana since executions are often enforced after trials in which the accused persons are 11 Ruling 23/1990 (X31) AB, Constitutional Court of Hungary, Judgment of 24 October 1990, Magyar Kozlony 15 | P a g e

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