Chapter 5 • Human Rights and Arrest, Pre-Trial and Administrative Detention The European Court has further held that the terms of article 5(2) are “to be interpreted ‘autonomously’, in particular in accordance with the aim and purpose” of article 5, “which are to protect everyone from arbitrary deprivations of liberty”. The term “arrest” thus “extends beyond the realm of criminal-law measures”, and the words “any charge” were not intended “to lay down a condition for its applicability, but to indicate an eventuality of which it takes account”.104 This interpretation is also supported by the close link between article 5(2) and (4), because “any person who is entitled to take proceedings to have the lawfulness of his detention decided speedily cannot make effective use of that right unless he is promptly and adequately informed of the reasons why he has been deprived of his liberty”.105 Consequently, the European Court found a violation of article 5(2) in a case where a woman who was in hospital to receive treatment on a voluntary basis was subsequently placed in isolation and informed “that she was no longer free to leave when she wished because of an order made ten days previously”. The Court considered that neither “the manner” in which the applicant was informed, “nor the time it took to communicate this information to her, corresponded to the requirements” of article 5(2).106 In a case where the applicant, on the very day of his arrest, had been given a copy of the arrest warrant that “set out not only the reasons for depriving him of his liberty but also the particulars of the charges against him”, it found that article 5(2) had not been violated.107 ***** In order to comply with the requirement of information States may, as evidenced above, have to resort to interpreters. As expressly stated in Principle 14 of the Body of Principles for the Protection of All Persons under Any Form of Detention or Imprisonment, “a person who does not adequately understand or speak the language used by the authorities responsible for his arrest, detention or imprisonment is entitled to receive promptly in a language which he understands” information regarding, inter alia, the charges against him and the records of his arrest. A person deprived of his or her liberty must be promptly informed of the reasons therefor, in a language which he or she understands and in sufficient detail so as to be enabled to request a prompt decision by a judicial authority on the lawfulness of his or her deprivation of liberty. 104 Eur. Court HR, Van der Leer Case v. the Netherlands, judgment of 21 February 1990, Series A, No. 170-A, p. 13, para. 27. 105 Ibid., para. 28. 106 Ibid., paras. 30-31. 107 Eur. Court HR, Lamy Case v. Belgium, judgment of 30 March 1989, Series A, No. 151, p. 17, para. 32. 184 Human Rights in the Administration of Justice: A Manual on Human Rights for Judges, Prosecutors and Lawyers