by a lawyer. The Court has also held that the gravity of the offense that the person is charged with is not, per se, sufficient grounds for pre-trial detention.130 102. The Court considers that the only legitimate purposes of pre-trial detention should be those that are directly involved in the adequate development of the proceedings; in other words, danger of flight, specifically mentioned in Article 7(5), and avoidance that the accused obstruct the development of the proceedings. 103. It should be noted that, prior to the order of Mr. Romero Feris’ pre-trial detention, the CSJN jurisprudence developed this standard in a decision of December 22, 1998, when it stated “that the legislative authority, with broad latitude to order, consolidate, distinguish and classify the purpose of the law […] and to thus establish regimes other than imprisonment, can only be justified when pre-trial detention is ordered on a procedural issue- thus preserving its purpose of avoiding that justice is frustrated […] in other words, that the accused evades or obstructs the investigations.”131 104. The CSJN, in a decision of October 3, 1997, also held that “a mere reference to the punishment available for the crime for which the person has been accused and to a prior conviction, without indicating the specific circumstances of the case, that would fundamentally allow the presumption that the accused will attempt to frustrate the action of justice, is not a valid justification for a judge’s decision that expresses the will to deny the requested benefit.”132 105. Finally, the Court is aware of developments in the European Court regarding the manner in which the elements of the legitimate purpose are substantiated. That Court has stated that “the risk of flight cannot solely be measured taking into consideration only the gravity of the offence.” It must be evaluated with reference to a series of other relevant factors that can confirm the existence of a risk of flight,133 as for example those related to a fixed residence, job, belongings, family and all types of ties to the country in which he or she is being tried.134 The European Court has also held that the danger that the accused obstruct the adequate development of the proceedings cannot be abstractly inferred, but rather it must be supported by objective evidence, for example the risk of tampering witnesses135 or of belonging to a criminal organization or a gang.136 106. With respect to necessity, the Inter-American Court considers that, since the deprivation of liberty is a measure that implies a restriction to the individual’s sphere of action, the judicial authority can only impose such a measure when it finds that the other legal mechanisms that offer a lower grade of interference on individual rights are not sufficient to satisfy the procedural purpose.137 107. In the European system, this position has had a special importance. The Council of Europe assumes as a general principle the exceptional nature of pre-trial detention. It Cf. Case of Bayarri v. Argentina. Preliminary Objection, Merits, Reparations and Costs. Judgment of October 30, 2008. Series C No. 187, para. 74 and Case of Pollo Rivera et al. v. Peru, para. 122. 130 131 Cf. CSJN. Case of Nápoli, Érika Elizabeth et al., Judgment of December 22, 1998, Merits 7. 132 Cf. CSJN. Case of Estévez, José Luis, Judgment of October 3, 1997, Considerations 6. Cf. ECHR. Case of Idalov v. Russia, Judgment of May 22, 2012, Application N° 5826/03, para.145 and Case of Panchenko v. Russia, Judgment of June 11, 2005, Application N° 11496/05, paras. 102 and 106. 133 Cf. ECHR. Case of Becciev v. Moldava, Judgment of October 4, 2005, Application N° 9190/03, para. 58 and Case of Sulaoja v. Estonia, Judgment of February 15, 2005, Application N° 55939/00, para. 64. 134 135 Cf. ECHR. Case of Jarzyński v. Poland, Judgment of January 4, 2006, Application N° 15479/02, para. 43. Cf. ECHR. Case of Štvrtecký v. Slovakia, Judgment of September 5, 2018, Application N° 55844/12, para. 61 and Case of Podeschi v. San Marino, Judgment of September 18, 2017, Application N° 66357/14, para. 149. 136 Cf. Case of Chaparro Álvarez and Lapo Íñiguez v. Ecuador, para. 93 and Case of Amrhein et al. v. Costa Rica, para. 356. 137 21