The right to a fair trial, as protected by Article 6 of the European Convention on Human Rights, guarantees the right of all defendants to participate effectively in their trial (Stanford v United Kingdom [1994] ECHR 16757/90 at [22]). In Stanford v UK, the European Court of Human Rights stated that the right to effective participation in the trial necessarily includes, amongst others things, the right of an accused to be present and to hear and follow the proceedings, and is ‘implicit in the very notion of an adversarial procedure’. Effective participation is also reflected in the specific rights of the accused listed in Article 6(3) of the European Convention – ‘to defend himself in person’, ‘to examine or have examined witnesses’ and ‘to have the free assistance of an interpreter if he cannot understand or speak the language used in court’.