justice and requires that one‟s cause be heard by efficient and impartial courts106. 196. Article 7(1) (d) of the African Charter enshrines “the right to be tried within a reasonable time by an impartial Court or tribunal.” The requirement of impartiality in Article 7 is complemented by Article 26 of the African Charter which imposes on States parties “the duty to guarantee the independence of the Courts” in their respective territories. 197. These obligations are captured in the Commission‟s Principles and Guidelines on Fair Trial where the Commission has expounded on what should be required for an independent and impartial tribunal. Among other criteria, the Principles and Guidelines on Fair Trial state that: - judicial bodies shall be established by law to have adjudicative functions to determine matters within their competence on the basis of the rule of law and in accordance with proceedings conducted in the prescribed manner;107 - there should not be any inappropriate or unwarranted interference with the judicial process nor shall decisions be subject to revision except through judicial review;108 - all judicial bodies shall be independent from the Executive branch109 and the government shall respect that independence;110 - the process of appointments to judicial bodies shall be transparent;111 - the judicial body shall decide matters before it without any restrictions, improper influence, inducements, pressure, threats or interference, direct or indirect, from any quarter or for any reason.112 106 Communication 281/2003 - Marcel Wetsh’okonda Koso and Others v Democratic Republic of Congo. See also Communication 151/96 - Civil Liberties Organisation v Nigeria, 107 Principles and Guidelines on Fair Trial (above n. Section A(4)(b). 108 Ibid., Section A(4)(f). 109 Ibid., Section A(4)(g). 110 Ibid., Section A(4)(a). 111 Ibid., Section A(4)(h) 59