of defense is expressed in two facets within the criminal proceeding: on the one hand, through the defendant’s own actions, the central component of which is the possibility of making a free statement on the facts attributed to him and, on the other hand, through the technical defense exercised by a legal professional, who advises the accused on his rights and duties and who also exercises, inter alia, a critical and legal control in the production of evidence.91 101. The right to receive prior and detailed notification of a criminal accusation means that it is necessary to provide a full description of the conduct attributed to the defendant, including factual information regarding the charges, which constitutes an essential reference document for the defendant to be able to defend himself and for the judge to consider in his decision. Therefore, the defendant has the right to be informed of the facts of which he is accused, described in a clear, detailed and precise manner.92 As part of the minimum guarantees established in Article 8(2) of the Convention, the right to prior and detailed notification of the charges applies both to criminal matters and to other matters indicated in Article 8(1) of the Convention, even though the information required in the other matters may be less and of a different nature.93 Another fundamental right is the right to have adequate time and means to prepare a defense, as established in Article 8(2)(c) of the Convention. This requires the State to ensure the defendant’s access to information in the case file against him. Furthermore, the State must respect the adversarial principle, which guarantees the defendant’s involvement in the analysis of the evidence.94 102. The Commission indicated that the alleged victim did not receive complete and detailed information regarding the charges made against him, and their justification, to be able to fully exercise his right to defense, since he was not notified of the prosecutor’s indictment. For its part, the State indicated in general terms that Mr. Grijalva was duly notified of all the judicial actions through his defense attorney. In addition, with respect to the prosecutor’s report, the State argued that the alleged victim submitted several observations, as is evident in the brief of July 31, 1996. 103. It has been proven that on November 29, 1993, the Commander of the First Naval Zone ordered the opening of a summary inquiry against Mr. Grijalva Bueno and another person. On November 30, 1993, the court of the First Naval Zone opened the summary inquiry, indicated the acts committed by the accused and ordered a number of procedures, including the taking of statements from the defendants, for which purpose Mr. Grijalva was summoned and ordered to provide an unsworn statement. The order to initiate proceedings was issued on June 15, 1994, and Mr. Grijalva was notified on July 5, 1995. Subsequently, on July 16, 1996, the prosecutor’s report was issued, regarding which the defendants requested its notification. Said report was notified to them on July 23, 1996, and on July 31, 1996, Mr. Grijalva Bueno and JS submitted their written observations (supra paras. 70 and 71). Cf. Case of Barreto Leiva v. Venezuela. Merits, reparations and costs, supra, para. 61, and Case of Valenzuela Ávila. Merits, reparations and costs. Judgment of October 11, 2019. Series C No. 386, para. 111. 92 Cf. Case of Fermín Ramírez v. Guatemala. Merits, reparations and costs. Judgment of June 20, 2005. Series C No. 126, para. 67, and Case of Urrutia Laubreaux v. Chile, Preliminary objections, merits, reparations and costs, supra, para. 113. 93 Cf. Case of Maldonado Ordóñez v. Guatemala. Preliminary objection, merits, reparations and costs, supra, para. 80, and Case of Urrutia Laubreaux v. Chile. Preliminary objections, merits, reparations and costs, supra, para. 113. 94 Case of Palamara Iribarne v. Chile. Merits, reparations and costs, supra, para. 170, and Case of Álvarez Ramos v. Venezuela. Preliminary objection, merits, reparations and costs. Judgment of August 30, 2019. Series C No. 380, para. 153. 91 27