31According to the case-law of the European Court of Human Rights, the concept of a fair trial' referred to in Article 6 of the ECHR consists of various elements, which include, inter alia, the rights of the defence, the principle of equality of arms, the right of access to the courts, and the right of access to a lawyer both in civil and criminal proceedings (see Golder v United Kingdom, judgment of 21 February 1975, Series A No 18, §§ 26 to 40; Campbell and Fell v United Kingdom, judgment of 28 June 1984, Series A No 80, §§ 97 to 99, §§ 105 to 107 and §§ 111 to 113; and Borgers v Belgium, judgment of 30 October 1991, Series A No 214-B, § 24).
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