46 2. Every person accused of a criminal offense has the right to be presumed innocent so long as his guilt has not been proven according to law. During the proceedings, every person is entitled, with full equality, to the following minimum guarantees: a. The right of the accused to be assisted without charge by a translator or interpreter, if he does not understand or does not speak the language of the tribunal or court; b. Prior notification in detail to the accused o the charges against him; c. Adequate time and means for the preparation o his defense; d. The right of the accused to defend himself personally or to be assisted by legal counsel of his own choosing, and to communicate freely and privately with this counsel; e. The inalienable right to be assisted by counsel, provided by the state, paid or not as the domestic law provides, if the accused does not defend himself personally or engage his own counsel within the time period established by law; f. The right of the defense to examine witnesses present in the court and to obtain the appearance, as witnesses, of experts or other persons who may throw light on the facts; g. The right not to be compelled to be a witness against himself or to plead guilty, and h. The right to appeal the judgment in a higher court. A. ADMINISTRATIVE PROCEDURE 101. As we have established, the Migration and Naturalization Directorate, an administrative body, was the authority that issued the “directorial resolution” that annulled Mr. Ivcher Bronstein’s nationality title. Consequently, the Court deems that, in the context of the administrative procedure, it is pertinent to consider how Article 8 of the American Convention applies to the facts of this case. 102. Although Article 8 of the American Convention is entitled “Right to a Fair Trial”, its application is not limited strictly to judicial remedies, “but to a series of requirements that must be observed by the procedural bodies 83” so that a person may defend himself adequately against any act of the State that could affect his rights84. 103. The Court has established that, although this article does not stipulate minimum guarantees in matters which concern the determination of the rights and obligations of a civil, labor, fiscal or any other nature, the minimum guarantees established in paragraph 2 of the article should also apply to those categories and, therefore, in that respect, a person has the right to due process in the terms recognized for criminal matters, to the extent that it is applicable to the respective procedure85. 83 Cf. Judicial Guarantees in States of Emergency (Articles 27(2), 25 and 8 American Convention on Human Rights). Advisory Opinion OC-9/87 of October 6, 1987. Series A No. 9, para. 27 84 Cf. Constitucional Tribunal case, supra note 8, para. 69.