CCPR/C/GC/32 Page 17 Covenant.115 Furthermore, it does not guarantee ne bis in idem with respect to the national jurisdictions of two or more States.116 This understanding should not, however, undermine efforts by States to prevent retrial for the same criminal offence through international conventions.117 X. RELATIONSHIP OF ARTICLE 14 WITH OTHER PROVISIONS OF THE COVENANT 58. As a set of procedural guarantees, article 14 of the Covenant often plays an important role in the implementation of the more substantive guarantees of the Covenant that must be taken into account in the context of determining criminal charges and rights and obligations of a person in a suit at law. In procedural terms, the relationship with the right to an effective remedy provided for by article 2, paragraph 3 of the Covenant is relevant. In general, this provision needs to be respected whenever any guarantee of article 14 has been violated.118 However, as regards the right to have one’s conviction and sentence reviewed by a higher tribunal, article 14, paragraph 5 of the Covenant is a lex specialis in relation to article 2, paragraph 3 when invoking the right to access a tribunal at the appeals level.119 59. In cases of trials leading to the imposition of the death penalty scrupulous respect of the guarantees of fair trial is particularly important. The imposition of a sentence of death upon conclusion of a trial, in which the provisions of article 14 of the Covenant have not been respected, constitutes a violation of the right to life (article 6 of the Covenant).120 60. To ill-treat persons against whom criminal charges are brought and to force them to make or sign, under duress, a confession admitting guilt violates both article 7 of the Covenant prohibiting torture and inhuman, cruel or degrading treatment and article 14, paragraph 3 (g) prohibiting compulsion to testify against oneself or confess guilt.121 61. If someone suspected of a crime and detained on the basis of article 9 of the Covenant is charged with an offence but not brought to trial, the prohibitions of unduly delaying trials as provided for by articles 9, paragraph 3, and 14, paragraph 3 (c) of the Covenant may be violated at the same time.122 Communication No. 1001/2001, Gerardus Strik v. The Netherlands, para. 7.3. Communications No. 692/1996, A.R.J. v. Australia, para. 6.4; No. 204/1986, A.P. v. Italy, para. 7.3. 117 See, e.g. Rome Statute of the International Criminal Court, article 20, para. 3. 118 E.g. Communications No. 1033/2001, Singarasa v. Sri Lanka, para. 7.4; No. 823/1998, Czernin v. Czech Republic, para. 7.5. 119 Communication No. 1073/2002, Terrón v. Spain, para. 6.6. 120 E.g. communications No. 1044/2002, Shakurova v. Tajikistan, para. 8.5 (violation of art. 14 para. 1 and 3 (b), (d) and (g)); No. 915/2000, Ruzmetov v. Uzbekistan, para.7.6 (violation of art. 14, para. 1, 2 and 3 (b), (d), (e) and (g)); No. 913/2000, Chan v. Guyana, para. 5.4 (violation of art. 14 para. 3 (b) and (d)); No. 1167/2003, Rayos v. Philippines, para. 7.3 (violation of art. 14 para. 3(b)). 121 Communications No. 1044/2002, Shakurova v. Tajikistan, para. 8.2; No. 915/2000, Ruzmetov v. Uzbekistan, paras. 7.2 and 7.3; No. 1042/2001, Boimurodov v. Tajikistan, para. 7.2, and many others. On the prohibition to admit evidence in violation of article 7, see paragraphs. 6 and 41 above. 122 Communications No. 908/2000, Evans v. Trinidad and Tobago, para. 6.2; No. 838/1998, Hendricks v. Guayana, para. 6.3, and many more. 115 116