which the claim to refugee status or asylum is based; to deal with cases where refugees or asylum-seekers have destroyed their travel and/or identity documents […] or to protect national security or public order”.62 In addition, the case law of the UN Human Rights Committee provides that detention of non-citizens may be arbitrary under the International Covenant on Civil and Political Rights if “it is not necessary in all the circumstances of the case and proportionate to the ends sought.”63 215. In relation to the assertion of the Complainant that the arrest was “random” and the detention “arbitrary”, the Commission has to determine whether the arrest was necessary, reasonable, and proportionate to a legitimate government objective. One of the grounds given by the State for why the people were rounded up is the belief on the part of the State, based on the declaration by UNHCR, that the protestors included persons who do not meet the refugee criteria as well as illegal migrants. This is supported by the actions of the State, which included the release the following day of all people with legal residence permits and persons from Darfur, a region which at the time was known to be in crisis. Given that initial identification is one of the circumstances in which detention may be justified, and that women and children, in addition to people with legal residence permits and persons from Darfur were released the following day, the Commission finds that taking the protesters into detention was not arbitrary, as it served a legitimate government purpose and was not disproportionate. 216. Besides the proper justification of detention, the right to liberty also includes procedural components. However, immigration detention proceedings are often accompanied by fewer procedural safeguards than criminal proceedings, since it is considered to be an administrative procedure. The main procedural safeguards include the right to review of detention; and right to communicate and consult with legal counsel of his choice. According to the UN Body of Principles (§13), “[any] person shall, at the moment of arrest and at the commencement of detention or imprisonment, or promptly thereafter, be provided by the authority responsible for his arrest, detention or imprisonment, respectively with information on and an explanation of his Detention of Refugees and Asylum-Seekers No. 44 (XXXVII) – 1986 Executive Committee 37th session. Contained in United Nations General Assembly Document No. 12A (A/41/12/Add.1). 63 A. v. Australia. (1997) 560/1993; Danyal Shafiq v. Australia (2006) 1324/2004. 62 59