.. ,' definition of the United Nations Human Rights Commission. On .arbitrary 1 detention, the Working Group considered as "arbitrary", instances of denial of liberty, which for one reason or another, are contrary to the relevant international norms enunciated in the Universal Declaration of Human Rights, or instances which are so considered by the relevant international instruments ratified by the States. To determine the arbitrary nature of a detention, the Working Group set out three criteria, namely that: - It shall be manifestly impossible to invoke any legal basis whatsoever to ju stify the denial of liberty; - Denial of liberty shall be' corollary to the exercise of rights _or freedoms stipulated by Articles 7, 13, 14, 18, 19, 20 and 21 of the Universal States Declaration of Human Rights, in as far as the are parties to the International Covenant on Civil and Political Rights; ' - Non-observance, be it total or norms relating right to the Universal Declaration to fair partial, of the international trial, as enunciated in the of Human Rights and in the international instruments r a t i f i e d b y t h e s t a t e s concerned, is of such gravity as the denial of liberty i s of an arbitrary nature. 34. On the whole, Sow Bertin Agba was illegally held in prison for 9 months and 21 days, aside of the fact that he was held in custody for 16 days for the purposes of the preliminary inquiry on the premises of the National Intelligence Agency (ANR) Gendarmerie. 35. Since the detention of the Applicant is not on any legal basis, it is arbitrary, and violates the provisions of the following legal instruments ratified by the Republic of Togo: 36. Article 9 of the 10 December 1948 Universal Declaration of Human Rights, which provides that: "No one shall be subjected to arbitrary arrest, detention or exile"; Article .9(1) of the International Covenant on Civil and Political Rights: 10