proceedings before a court to test the lawfulness of detention), since the complainant had no access to legal representation from December 1984 to March 1985, and was therefore not in due time afforded the opportunity to obtain, on his own initiative, a decision by a court on the lawfulness of his detention. 656. In case No. 336/1988 (Nicole Fillastre v. Bolivia), the Committee found a violation of article 9, paragraphs 2 and 3. It observed: "Under article 9, paragraph 3, anyone arrested or detained on a criminal charge 'shall be entitled to trial within a reasonable time , ,.*. What constitutes 'reasonable time9 is a matter of assessment for each particular case. The lack of adequate budgetary appropriations for the administration of criminal justice alluded to by the State party does not justify unreasonable delays in the adjudication of criminal cases. Nor does the fact that investigations into a criminal case are, in their essence, carried out by way of written proceedings, justify such delays. In the present case, the Committee has not heexi informed that a decision at first instance had been reached some four years after the victims' arrest. Considerations of evidence-gathering do not justify such prolonged detention. The Committee concludes that there has been, in this respect, a violation of article 9, paragraph 3." (annex IX, sect. K, para. 6.5) 657. Violations of article 9 were also found in cases Kos. 277/1988 (Juan Teran Jijon v. Ecuador), 289/1988 (Dieter Wolf v. Panama) and 319/1988 (Edgar A. Canon Garcia v. Ecuador). (d) Treatment during imprisonment (Covenant, art. 10) 658. Article 10, paragraph 1, prescribes that all persons deprived of their liberty shall be treated with humanity and with respect for the inherent dignity of the human person, in case No. 289/1988 (Dieter Wolf v. Panama), the author claimed that he had been ill-treated during detention and confined to a special cell, together with a mentally disturbed prisoner, who allegedly had killed several other inmates. In the same context, he stated that all his property had been stolen in prison and that he had been denied food for five days. The State party did not address the claim of maltreatment, and the Committee found tnat the physical ill-treatment, and the denial of food for five days did violate the author's right under article 10, paragraph 1 (annex IX, sect. K ) . 659. In cases Nos. 240/1987 (Willard Collins v. Jamaica), 271/1988 (Clyde Sutcliffe v. Jamaica) and 277/1988 (Juan Teran Jijon v. Ecuador), the Committee found that a violation of article 7 (see sect, (b) above) also entailed a violation of article 10, paragraph 1. 660. Paragraph 2 of article 10 gives accused persons the right to be segregated from convicted prisoners and to be subjected to separate treatment appropriate to their status as unconvicted persons. In case No. 289/1988 (Dieter Wolf v. Panama) the author was detained for a period of over a year at a penitentiary for convicted prisoners, while he was unconvicted and awaiting trial. The Committee found that this amounted to a violation of the author's right under article 10, paragraph 2 (annex IX, sect. K ) . -156-