as “ICCPR”),27 establishes the right to free legal assistance as a part of the general right to fair trial. The right to free legal assistance arises where a person cannot afford to pay for legal representation and where the interests of justice so require.28 The interests of justice also require the provision of free legal assistance where, among others, the Applicant is indigent, the offence he/she is facing is serious and the penalty provided by the law is severe.29 74. The Court confirms, from the record, that the Applicants conducted their case without the assistance of counsel throughout all domestic proceedings. As against this, the Court observes that the Applicants were charged with a serious offence, to wit, gang rape, which carries a mandatory sentence of life imprisonment on conviction. In the circumstances, the interests of justice required that they should have been provided with free legal assistance. This obligation persisted regardless of whether or not the Applicants requested for free legal assistance. 75. The Court, therefore, holds that the Respondent State has violated Article 7(1)(c) of the Charter, as read together with Article 14(3)(d) of the ICCPR, due to its failure to accord the Applicants free legal assistance during proceedings before domestic courts. VIII. REPARATIONS 76. Article 27(1) of the Protocol provides that: If the Court finds that there has been violation of a human or peoples’ rights, it shall make appropriate orders to remedy the violation, including the payment of fair compensation or reparation. 27 The Respondent State became a party to the International Covenant on Civil and Political Rights on 11 June 1976. 28 Thomas v. Tanzania (merits), supra, § 114. 29 See also Abubakari v. Tanzania (merits), supra, and Anaclet Paulo v. United Republic of Tanzania (merits) (21 September 2018) 2 AfCLR 446, § 92. 19