The concept of ‘equality of arms’ was first mentioned in the Neumeister case, and has been a feature of Article 6(1) ever since. It requires a fair balance between the parties and applies to both civil and criminal cases.
By way of another, rather glaring, example, the Court found a violation of Article 6(1) in criminal proceedings where the defence lawyer was made to hang around for fifteen hours before finally being given a chance to plead his case in the early hours of the morning. (cu trimitere la Makhfi v France, 19 October 2004).
Bernadette Rainey, Elizabeth Wicks, Clare Ovey
(Jacobs, White, and Ovey: The European Convention on Human Rights, Oxford University Press, ediția a 7 a, data apariției: 14 septembrie 2017, la pp. 291-2)