The African Commission on Human and Peoples’ Rights concluded that Burundi had violated the right to

a defense in article 7(1)(c) of the African Charter on Human and Peoples’ Rights in a case where the courts
had refused to designate a defense lawyer to an accused person who was eventually sentenced to death.
The Commission “emphatically” recalled that “the right to legal assistance is a fundamental element of
the right to fair trial”, in particular in cases “where the interests of justice demand it”. Given “the gravity
of the allegations brought against the accused” person in this case “and the nature of the penalty he faced,
it was in the interests of justice for him to have the benefit of the assistance of a lawyer at each stage of
the case”.116 Article 7(1)(c) of the African Charter was also violated in a death penalty case against Nigeria
where the defense counsel for the seven complainants “was harassed and intimidated to the extent of
being forced to withdraw from the proceedings. In spite of this forced withdrawal of counsel, the tribunal
proceeded to give judgement in the matter, finally sentencing the accused to death”. In the view of the
Commission the defendants were thus “deprived of their right to defense, including their right to be
defended by counsel of their choice” contrary to article 7(1)(c) of the African Charter.117

Source: https://www.ohchr.org/Documents/Publications/training9chapter7en.pdf