119. In Benham v The United Kingdom21 , the applicant had been charged with non-payment of a debt and faced a maximum penalty of three (3) months in prison. The European Court held that this potential sentence was severe enough that the interests of justice demanded that the applicant ought to have benefited from legal aid. In Salduz v Turkey, the Court held that legal aid should be available for people accused or suspected of a crime, irrespective of the nature of the particular crime and that legal assistance is particularly crucial for people suspected of serious crimes.22 120. The Court draws inspiration from the jurisprudence of the Human Rights Committee on the interpretation and application of Article 14(3)(d) of the ICCPR. This is with respect to Anthony Currie v Jamaica, whose circumstances are similar to those of the Applicant in the case before this Court, as they both raised issues of compliance with constitutional guarantees of their rights to fair trial in their criminal trials and appeals. In this communication, the Human Rights Committee held that Article 14(3)(d) of the ICCPR required the provision of legal aid in the course of criminal proceedings, where the interests of justice so require."23 21 Application No 19380/92, Judgment of 10 June 1996 (Grand Chamber). 22 Application No. 36391/02, Sa/duz v Turkey, Judgment of 27 November 2008 (Grand Chamber) paragraph 54. 23 Communication Number 377/89 paragraph 13.2. "The author has claimed that the absence of legal aid for the purpose of filing a constitutional motion itself constitutes a violation of the Covenant. The Committee notes that the Covenant does not contain an express obligation as such for a State to provide legal aid for individuals in all cases but only, in accordance with article 14 (3) (d), in the determination of a criminal charge where the interests of justice so require". 46