Violation of Article 7(1)(c) 104. Article 7(1)(c) of the Charter stipulates that: “Every individual shall have the right to have his cause heard. This comprises: (c) The right to defence, including the right to be defended by counsel of his choice”. In his submissions, the Complainant raises two specific cases of violation of the right to defence: the impossibility for his lawyers to have access to the case file and the notification of a new charge in their absence at a crucial stage of the proceedings. 105. In its jurisprudence, the Commission has dealt with many cases on the right to defence.21 Regarding access to case files and legal representation, the Commission recalls its decision in the Saro-Wiwa case where it concluded that the right to defence was violated after “the defence was denied access to the evidence on which the prosecution was based and that files and documents which were required by the accused for their defence were removed from their residences and offices when they were searched by security forces”.22 106. Moreover, the right to defence stems from the need for the accused to be able to use the services of a specialist who is well informed about the procedure and the substantial issues, in order to guarantee his rights from the beginning of the proceedings. As such, in the case of Avocats Sans Frontières (on behalf of Bwampamye) v. Burundi, the Commission held that “the right to defence also implies that at each stage of the criminal proceedings, the accused and his counsel should be able to reply to the indictment of the public prosecutor and should, in any case, be the last See among others Civil Liberties Organisation and Others v. Nigeria Communication 218/98 (2001) AHRLR 75 (ACHPR 2001); Law Office of Ghazi Suleiman (I) v. Sudan op. cit.; Article 19 v. Eritrea Communication 275/03 (2007) AHRLR 73 (ACHPR 2007) 22 International Pen and Others (on behalf of Saro-Wiwa) v. Nigeria Communications 137/94, 139/94, 154/96 and 161/97 (2000) AHRLR 212 (ACHPR 1998) paras 99-101. 21 30