shortcomings in his counsel’s conduct in relation to his defence in this regard. 87. As emerges from the record of the appeal proceedings40 that the Applicant reported that Advocate Method R.G. Kabuguzi, who represented the prosecution during the preliminary hearing also represented the Applicant during his appeal, before the Court of Appeal. With regard to effective legal representation by an advocate under a Respondent State’s legal aid scheme, this Court has held that it is not sufficient for a State to simply provide free legal assistance. States must also ensure that lawyers provide robust representation at all stages of the legal process starting from the arrest of the individual for whom such representation is being provided.41 88. In the instant case, the Court notes that the records on file reveal that Advocate Method R.G. Kabuguzi represented both the Respondent State and the Applicant at the preliminary hearing and during the Court of Appeal trial respectively. This led the Court of Appeal to refer to his conduct as “inappropriate and unethical”.42 The Court of Appeal in its judgement observed that “Before us the appellant is represented by Mr. Method R.G. Kabuguzi, learned counsel. He also appeared for him at a certain stage in the trial court. When the preliminary hearing was conducted on 11th December 1998. Mr. Kabuguzi, learned Advocate was a State Attorney then, working with the Office of the Attorney General. He appeared in Court to prosecute the case on behalf of the Republic. His appearance before us to prosecute the appeal on behalf of the appellant is inappropriate and it is not ethical. Advocates should refrain from such practice.” Nevertheless, in spite of this observation, the Court of Appeal proceeded to hear the appeal on both sides on the basis that it did not prejudice the Applicant. 89. In examining the issue at hand, this Court finds it relevant to refer to The Bangalore Principles and Guidelines on the Right to A Fair Trial and Legal 40 Record of proceedings, Court of Appeal Judgement and Court of Appeal decision on Review. 41 Habyalimana v. Tanzania (merits and reparations), supra, § 99. 42 Judgement of 27 October 2019, page 5 and Court of Appeal’s decision on review, page 7. 24