45 deprivation of liberty of a punitive nature, free legal representation is an imperative for the interests of justice.150 147. In consequence, the Tribunal considers that the fact of not having provided the accused with the right to defense before the administrative instance, in which it was decided the application of the penalty of deprivation of liberty, has effects on the entire proceeding and goes beyond the decision of December 6, 2002. Certainly, the punitive administrative procedure is a single proceeding in various stages,151 including the processing of the remedies filed against the decision adopted. 148. Therefore, the Court considers that the State of Panama violated, to the detriment of Mr. Vélez Loor, the right to a hearing contained in Article 8(1) of the Convention and the right to be assisted by a counsel contained in Articles 8(2)(d) and 8(2)(e) of the Convention, in relation to Article 1(1) therein to the detriment of Mr. Vélez Loor. e) Right to information and effective access to consular assistance 149. The Commission referred to the omissions made by the State of Panama that “prevented the access to adequate and timely consular assistance.” In this respect, it argued that "the right to seek consular assistance implies that the person who was arrested or subjected to a proceeding be informed of his right to communicate with consular officials and be provided the means to do so,” which “did not occur in the instant case, given that the Panamanian State unilaterally decided to inform the Ecuadorian State of the situation, without providing the means so that the [alleged] victim could communicate with the consular officials and seek the assistance required.” Furthermore, the Commission noted that “there is no evidence that the State of Ecuador has officially been informed of the proceeding conducted against the [alleged] victim or of the criminal penalty that such proceeding could entail.” The representatives agreed with the Commission that “[t]he State neither informed [Mr. Vélez Loor] of his right to seek consular assistance.” They alleged that “said right is not satisfied with the sole notification by the authorities of the recipient State,” given that “it is the individual who is entitled to the right to information and consular notification; therefore, Panama should have informed Mr. Vélez, without delay, of his right to contact the consulate of his country and also guarantee the conditions to be able to do so, had he chosen.” 150. The State pointed out that the “Consulate of the Republic of Ecuador was notified, over the telephone, by the National Office of Immigration [...] of the detention of Mr. Vélez Loor, on November 12, 2002,” and that Mr. Vélez Loor had proven assistance of consular officials of his country “since the beginning of December, [2002].” Likewise, the State sustained that “at the time of the events, […] Panama, like most countries, applied its criterion regarding consular notification[, according to which] it understood that the right to consular notification was a right of the sending State, and not a right of the individual.” Therefore, the State considers that “[a]t the moment of the detention of Mr. Vélez , the notification served on the consul [of Ecuador] regarding the detention of the individual was, according to the 150 Cf. ECHR, Case of Benham v. The United Kingdom (Application no 19380/92) Judgment, 10 June 1996, para. 61 (“The Court agrees with the Commission that where deprivation of liberty is at stake, the interests of justice in principle call for legal representation”) and para. 64 (“In view of the severity of the penalty risked by Mr Benham and the complexity of the applicable law, the Court considers that the interests of justice demanded that, in order to receive a fair hearing, Mr Benham ought to have benefited from free legal representation during the proceedings before the magistrates”). 151 Cf. mutatis mutandi Case of Castillo Petruzzi et al. v. Perú. Merits, Reparations, and Costs. Judgment of May 30, 1999. Series C No. 52, para. 161; Case of Radilla Pacheco, supra note 25, para. 208, and Case of García Prieto et al. v. El Salvador. Preliminary Objections, Merits, Reparations, and Costs. Judgment of November 20, 2007. Series C No. 168, para. 43.