84 were allegedly guilty, or a person whose criminal liability had been clearly and sufficiently proven. 183. Based on the foregoing, the Court finds that the State breached Article 8(2) of the American Convention, to the detriment of Daniel Tibi. c) In regards to prior communication to the accused of the charges against him 184. Article 8(2)(b) of the American Convention establishes that [d]uring the proceedings, every person is entitled, with full equality, to the following minimum guarantees: b. prior notification in detail to the accused of the charges against him; 185. It has been established that Daniel Tibi was not informed in a timely and complete manner of the charges against him in the court order to investigate the alleged crime (supra para. 90(18)), on which charges his arbitrary detention had, in fact, been based. 186. In this regard, in General Observation No. 13 on “Equality before the courts and the right to a fair and public hearing by an independent court established by law (Art. 14)”, the Human Rights Committee of the United Nations pointed out that: the right to be informed of the charge "promptly" requires that information is given in the manner described as soon as the charge is first made by a competent authority. In the opinion of the Committee this right must arise when in the course of an investigation a court or an authority of the prosecution decides to take procedural steps against a person suspected of a crime or publicly names him as such. The specific requirements of subparagraph 3 (a) may be met by stating the charge either orally or in writing, provided that the information indicates both the law and the alleged facts on which it is based. 187. Article 8(2)(b) of the American Convention orders the competent judicial authorities to notify the accused of the charges against him, the reasons for them, and the crimes or infractions for which he is being accused, prior to the proceeding. For this right to fully operate and satisfy its inherent aims, it is necessary for said notification to take place before the accused renders his first statement. Without this guarantee, his right to adequately prepare his defense would be infringed. 188. It was proven in the sub judice case that the alleged victim was informed neither of the court order to investigate the alleged crime nor of the charges against him. 189. Therefore, this Court finds that the State breached Article 8(2)(b) of the American Convention to the detriment of Tibi. d) Regarding the Right to Defense 190. Articles 8(2)(d) and 8(2)(e) of the Convention set forth: [d]uring the proceedings, every person is entitled, with full equality, to the following minimum guarantees: [...]