the author's trial unfair within the meaning of article 14. Finding a violation of that article of the Covenant, the Committee noted that: "In respect of the issue of the significance of the time of death of the victim, the Committee begins by noting that the post-mortem on the deceased was performed on 1 September 1981 at approximately 1 p.m., and that the expert concluded that death had occurred 47 hours before. His estimate, which was not challenged, implied that the author was already in police custody when the deceased was shot. The information was available to the Court; given the seriousness of its implications, the Court should have brought it to the attention of the jury, even though it was not mentioned by counsel. Furthermore, even if the Judicial Committee of the Privy Council had chosen to rely on the facts relating to the post-mortem evidence, it could not have addressed the matter as it was introduced for the first time at that stage. In all the circumstances, and especially given that the trial of the author was for a capital offence, this omission must, in the Committee's view, be deemed a denial of justice. This remains so even if the placing of this evidence before the jury might not, in the event, have changed their verdict and the outcome of the case." (annex IX, sect. 0, para. 8.3) 666. In communication No. 491/1992 (J.L. v. Australia), the author complained that his obligation to contribute practising fees and mandatory professional indemnity insurance premiums to the Law Institute of the State of Victoria violated his rights under article 14, as the applicable regulations had been subject to the approval of the Chief Justice of the Supreme Court of Victoria; he thus challenged the impartiality of the court. In declaring the complaint inadmissible under article 3 of the Optional Protocol, the Committee noted: "... that the regulation of the activities of professional bodies and the scrutiny of such regulations by the courts may raise issues, in particular under article 14 of the Covenant. More particularly, the determination of any rights or obligations in a suit at law in relation thereto entitles an author to a fair and public hearing. It is in principle for States parties to regulate or approve the activities of professional bodies, which may encompass the provision for mandatory insurance schemes ... the fact that the practice of law is governed by the Legal Profession Practice Act of 1958 and that the rules providing for a practising fee and a professional indemnity insurance will have no effect unless approved by the Chief Justice does not lead in itself to the conclusion that the court, as an institution, is not an independent and impartial tribunal ..." (annex X, sect. GE, para. 4.3) 667. Pursuant to article 14, paragraph 3 (b), accused persons must have adequate time and facilities to prepare their defence. In finding a violation of this provision, the Committee held in case No. 283/1988 (Aston Little v. Jamaica): "The right of an accused person to have adequate time and facilities for the preparation of his defence is an important element of the guarantee of a fair trial and a corollary of the principle of equality of arms. In cases in which a capital sentence may be pronounced, it is axiomatic that sufficient time must be granted to the accused and his counsel to prepare the defence for the trial; this requirement applies to all the stages of -158-