CCPR/C/GC/32 Page 7 with regard to the specific class of individuals and offences at issue the regular civilian courts are unable to undertake the trials.37 23. Some countries have resorted to special tribunals of “faceless judges” composed of anonymous judges, e.g. within measures taken to fight terrorist activities. Such courts, even if the identity and status of such judges has been verified by an independent authority, often suffer not only from the fact that the identity and status of the judges is not made known to the accused persons but also from irregularities such as exclusion of the public or even the accused or their representatives38 from the proceedings;39 restrictions of the right to a lawyer of their own choice;40 severe restrictions or denial of the right to communicate with their lawyers, particularly when held incommunicado;41 threats to the lawyers;42 inadequate time for preparation of the case;43 or severe restrictions or denial of the right to summon and examine or have examined witnesses, including prohibitions on cross-examining certain categories of witnesses, e.g. police officers responsible for the arrest and interrogation of the defendant.44 Tribunals with or without faceless judges, in circumstances such as these, do not satisfy basic standards of fair trial and, in particular, the requirement that the tribunal must be independent and impartial.45 24. Article 14 is also relevant where a State, in its legal order, recognizes courts based on customary law, or religious courts, to carry out or entrusts them with judicial tasks. It must be ensured that such courts cannot hand down binding judgments recognized by the State, unless the following requirements are met: proceedings before such courts are limited to minor civil and criminal matters, meet the basic requirements of fair trial and other relevant guarantees of the Covenant, and their judgments are validated by State courts in light of the guarantees set out in the Covenant and can be challenged by the parties concerned in a procedure meeting the requirements of article 14 of the Covenant. These principles are notwithstanding the general obligation of the State to protect the rights under the Covenant of any persons affected by the operation of customary and religious courts. 25. The notion of fair trial includes the guarantee of a fair and public hearing. Fairness of proceedings entails the absence of any direct or indirect influence, pressure or intimidation or intrusion from whatever side and for whatever motive. A hearing is not fair if, for instance, the defendant in criminal proceedings is faced with the expression of a hostile attitude from the public or support for one party in the courtroom that is tolerated by the court, thereby impinging on the right to defence,46 or is exposed to other manifestations of hostility with similar effects. See communication No. 1172/2003, Madani v. Algeria, para. 8.7. Communication No. 1298/2004, Becerra Barney v. Colombia, para.7.2. 39 Communications No. 577/1994, Polay Campos v. Peru, para. 8.8; No. 678/1996, Gutiérrez Vivanco v. Peru, para. 7.1; No. 1126/2002, Carranza Alegre v. Peru, para. 7.5. 40 Communication No. 678/1996, Gutiérrez Vivanco v. Peru, para. 7.1. 41 Communication No.577/1994, Polay Campos v. Peru, para. 8.8; Communication No. 1126/2002, Carranza Alegre v. Peru, para.7.5. 42 Communication No. 1058/2002, Vargas Mas v. Peru, para. 6.4. 43 Communication No. 1125/2002, Quispe Roque v. Peru, para. 7.3. 44 Communication No. 678/1996, Gutiérrez Vivanco v. Peru, para. 7.1; Communication No. 1126/2002, Carranza Alegre v. Peru, para.7.5; Communication No. 1125/2002, Quispe Roque v. Peru, para. 7.3; Communication No. 1058/2002, Vargas Mas v. Peru, para. 6.4. 45 Communications No. 577/1994, Polay Campos v. Peru, para. 8.8 ; No. 678/1996, Gutiérrez Vivanco v. Peru, para. 7.1. 46 Communication No. 770/1997, Gridin v. Russian Federation, para. 8.2. 37 38