well as with the fundamental principles enunciated in the Universal Declaration of Human Rights Article 3 of which guarantees the right to life, liberty and security of the human person”. Even where a State have not ratified or adhered to any of the international human instruments stated above, it is nonetheless bound by other legal sources, especially Customary International Law to ensure that a person’s right to respect for his or her liberty and security. Article 9 (1) of the International Covenant on Civil and Political Rights provides as follows; “Everyone has the right to liberty and security of persons. No one shall be subjected to arbitrary arrest or detention. No one shall be deprived of his liberty except on such grounds and in accordance with such procedure as are established by law”. Similarly, Article 6 of the African Charter on Human and Peoples’ Rights provides that: “Every individual shall have the right to liberty and to security of his person. No one may be deprived of his freedom except for reasons and conditions previously laid down by law. In particular no one may be arbitrarily arrested or detained”. An analysis of these provisions suggests even if in different terms, that deprivation of liberty must in all cases be carried out in accordance with the law, (the principle of legality). Furthermore, deprivations of liberty must not be arbitrary. 30