the scope of Article 36 of the VCCR,22 to the Mexican Supreme Court's decision in the case of Florence Cassez23 to highlight the difficulties that foreign nationals face both from language and cultural standpoints. They also refer to decisions of the United States Court of Appeals for the 7th Circuit,24 the High Court of Malawi 25 and the Supreme Federal Court of Brazil 26 which have all stressed the fundamental character of consular notification and the enjoyment of related fair trial rights. 94. According to the Amici, the failure to respect the consular rights of a capital sentence defendant makes any subsequent execution an arbitrary deprivation of life that is contrary to Article 4 of the Charter. To that effect they refer to the African Commission's General Comment on the right to Iife. 27 The Amici aver that such violation requires substantial remedies notwithstanding the failure to raise that issue during the trial. 26 -* 95. The Court notes that, as it is stated in his own submissions and those of the Intervening State, the Applicant's claim is that the lack of consular assistance provided under Article 36(1) of the VCCR deprived him of the possibility to enjoy assistance from his country with respect to the protection of his fair trial rights. The Court further notes the Applicant specifically mentioned the rights to be assisted by an interpreter and a lawyer. 96. As this Court has found earlier, these rights accruing from the provision of Article 36(1) of the VCCR are also protected under Article 7(1 )(c) of the Charter. Having also concluded that the related claims made under Article 7(1)(c) of the Charter are 22 Advisory Opinion CC - 16/99 IACHR (1 October 1999) 'The ri9ht to information on consular assistance in the framework of the guarantees of the due process of law'. 23 Amparo Directo en Revision 517/ 2011 Florence Marie Cassez Crepin, Plena de la Suprema Corte de Justicia, pages 20-22. " Osagiede v United States. 25 High Court of Malawi, Sentence rehearing Case No 25 of 2017 (23 June 2017): The Republic v. Lamec/( Bendawe Phiri. S.T.F., Ext. No. 954, Relator: Joaquim Barbosa, 17.05.2005; 98 DIARIO DA JUSTICIA 24.05.2005 §.75. Other cases cited to that effect are: Mansaraj and Others v. Sierra Leone, International Pen and Others (on behalf of Saro-Wiwa) v. Nigeria, Yasseen & Thomas v. Guyana. "Avena and Other Mexican Nationals. (Mexico v. United States of America), Jud9ment, I.C.J. Reports 2004, p. 12, 121. 26 27 25