The Code of Criminal Procedure Act, 2008 likewise protects the right of legal representatives to consult their clients in preparing a defence. In Constitutional Rights Project v. Nigeria, Communication No. 60/91 (African Commission on Human and Peoples’ Rights, 1995), the Commission held that denying detainees access to legal counsel violated Article 7 of the African Charter. 46221/99, European Court of Human Rights, Grand Chamber, 2005), the Court emphasised that unjustified restrictions on access to legal counsel fundamentally impair the right to a fair trial. The United Nations Human Rights Committee reached the same conclusion in Conteris v. Uruguay, Communication No.