 confessions made under torture or ill-treatment were used by the Court; and  192. they were denied the right of appeal. The essential question that must be asked here is whether the trial of the Victims complied with the provisions of Articles 7(1) and 26 of the African Charter. 193. Article 7 of the African Charter provides that: “Every individual shall have the right to have his cause heard. This comprises: a) The right to an appeal to competent national organs against acts violating his fundamental rights as recognized and guaranteed by the conventions, laws, regulations, and customs in force; b) The right to be presumed innocent until proven guilty by a competent court or tribunal; c) The right to defence, including the right to be defended by counsel of his choice; d) The right to be tried within a reasonable time by an impartial court or tribunal. 194. Article 26 on its part provides that: „States Parties to the present Charter shall have the duty to guarantee the independence of the courts and shall allow the establishment and improvement of appropriate national institutions entrusted with the promotion and protection of the rights and freedoms guaranteed by the present Charter‟. 195. A combined reading of Articles 7 and 26 brings to the fore two core issues – having access to appropriate justice and the other relating to the independence of justice system. These two issues constitute the bedrock of a sound justice delivery system. The African Commission believes that the right to a fair trial is analogous with the concept of access to appropriate 58