Right to counsel


In criminal law, the right to counsel means a defendant has a legal right to have the assistance of counsel and, if the defendant cannot afford a lawyer, requires that the government appoint one or pay the defendant's legal expenses. The right to counsel is generally regarded as a constituent of the right to a fair trial. Historically, however, not all countries have always recognized the right to counsel. The right is often included in national constitutions. Of the 194 constitutions currently in force, 153 have language to this effect.

Around the world

Australia

In Australia, suspects and defendants have the right to have legal representation during investigation and trial. Those under investigation in general have the right to have an attorney present during questioning, but there are exceptions to this right. Australian law does not recognize a right to publicly-funded legal defense, but does recognize that in the absence of counsel the accused may not receive a fair trial as mandated by law. Only the states of New South Wales and Victoria have dedicated public defender systems. Courts have the power to stay proceedings when they determine there is a risk of unfair trial. The High Court of Australia ruled in Dietrich v The Queen that while indigent defendants are not entitled to legal defense as a guaranteed right, a judge should typically grant a request for an adjournment or stay in most serious criminal cases where a defendant is unrepresented, and should allow a trial where a defendant accused of a serious criminal offense is left unrepresented to proceed only in exceptional circumstances.
Each state and territory of Australia has a Legal Aid Commission to provide legal services in criminal, civil, and family law matters to the indigent, but will only assist those who meet their threshold criteria, particularly with regard to income. Anyone accused of a Commonwealth crime, or crime falling within the jurisdiction of the federal government, has the right to ask a judge for counsel within two weeks of committal, and the judge may appoint a lawyer if convinced that the defendant cannot afford counsel. A network of community legal centres also exists to provide legal services free of charge to poor people who do not qualify for Legal Aid. Although they receive federal and state funding, they are independent non-profit organizations which rely on lawyers to staff them on a volunteer basis. Most cannot adequately keep up with demand and must turn some people away. Those who cannot obtain any kind of legal assistance may go unrepresented if they cannot pay for a lawyer.

Brazil

The Constitution of Brazil declares that all defendants have right to counsel, and mandates that all defendants who cannot pay for an attorney are entitled to state-funded legal representation in all criminal and civil cases. Public defender's offices exist at both state and federal levels as mandated by the constitution. A person must formally declare that they cannot afford regular legal aid to benefit from public defenders' services.

Canada

In Canada, the right to counsel is guaranteed under Section Ten of the Canadian Charter of Rights and Freedoms upon "arrest and detention", as well as the right to habeas corpus. Police must inform those arrested or detained of their right to speak to counsel and provide them with a reasonable opportunity to do so. However, this does not include an absolute right to have a lawyer present during interrogation unless the accused is under the age of 18. In October 2010, the Supreme Court of Canada affirmed in the case R v Sinclair that the right to counsel during interrogation is not absolute. It said that importing US-style Miranda rights was not in the interests of Canada. The ruling was a bare majority ruling, with a strenuously voiced minority opinion stating that it would lead to more false confessions and wrongful convictions.

China

According to Article 125 of the Constitution of the People's Republic of China and Article 11 of the Criminal Procedure Law of 1996, Chinese citizens have the right to legal counsel in court. The accused's right to counsel in China only comes into being once a case goes to trial. It does not exist at the investigative stage. A suspect under investigation only has the right to retain a lawyer to assist in securing bail, making procedural complaints, and seeking details from the police on the nature of the crime alleged, and not to start building a defense. A suspect gains the right to retain a lawyer upon having been interrogated or subjected to movement restrictions by the authorities. In cases defined as involving state secrets, the right to counsel is more heavily restricted: a lawyer may only be appointed to assist the suspect with the investigating body's permission. Chinese law allows courts to appoint a lawyer for a defendant unable to hire one, and it is mandatory for courts to appoint a lawyer to the blind, deaf, and mute, minors, and anyone facing the death penalty. The Chinese government operates thousands of legal aid centers nationwide for indigent defendants. The provincial governments rather than the central government are responsible for setting the threshold at which an economically disadvantaged person meets the criteria for legal assistance.
In 2022, Chinese justice agencies issued the Opinions on Further Deepening Pilot Efforts on Having Defense Counsel in All Criminal Cases, which translates to Guidelines for Improving Access to Defense Counsel in Criminal Cases. The guidelines specify procedures to involve defense counsel during both the trial stage and the prosecutorial charging stage. Under these guidelines, where an accused has not retained counsel and meets specified criteria, such as facing a felony-level sentence, involvement in a complex or high-profile case, or refusal to plead guilty, the prosecutor’s office or court must notify public defender offices or legal aid organizations to provide court-appointed counsel or arrange assigned counsel. The guidelines also require prompt appointment of counsel and interagency coordination to ensure that appointed or assigned lawyers are named within a few days, gain access to discovery and prosecutorial materials, and can counsel on plea negotiations and other procedural rights throughout the criminal process.

Ethiopia

The right to counsel is considered a constitutional right in Ethiopia. As per Article 20 of the Constitution of Ethiopia, "Accused persons have the right to be represented by legal counsel of their choice, and, if they do not have sufficient means to pay for it and miscarriage of justice would result, to be provided with legal representation at state expense." Ethiopia has public defender systems at both the federal and regional levels, however problems exist with public defense services being inadequate in some areas. A public defender can be assigned on request of the defendant or if the court so chooses. In addition to the public defender system, the Ethiopian judicial system also provides for private attorneys to offer pro bono representation to indigent defendants. Article 49 of the Federal Court Advocates’ Code of Conduct mandates that private attorneys must offer a minimum of 50 hours of legal representation for free or with minimum payment every year.

France

The Napoleonic Code of Criminal Instruction, adopted in France in 1808 and inspiring many similar codes in civil law countries, made it compulsory that the defendant should have a lawyer when tried in the assize courts. All criminal defendants in France enjoy right to counsel, and there is also a right to counsel in civil and administrative cases. State-funded legal aid for those facing criminal, civil, and administrative cases is available to those legally resident in France, and in some cases can be used for cases in another jurisdiction in Europe. Eligibility is means-tested, with a sliding scale of support based on income. Those at or below the lowest threshold are entitled to full legal assistance with all costs paid by the state, while higher-income individuals are entitled to have only 55% or 25% of their legal costs covered, depending on their income. State-funded legal advice is provided through a network of public legal advice centers throughout France. Some centers offer free legal advice to anyone living in the department while others restrict their services to those with modest incomes.

Germany

In Germany, it is mandatory that all defendants charged with a crime carrying a penalty of at least one year in prison have legal counsel, even if they themselves do not wish to have it, and the court will appoint a lawyer to represent a defendant who has not done so. There is no organized public defender system in Germany. The court can appoint any lawyer as counsel to a specific defendant, and a defendant may select a specific lawyer. The defendant will not be charged for legal services if acquitted, but will be liable to pay the lawyer's expenses if convicted unless the court finds that the defendant is indigent. In civil cases, the state provides legal representation, legal advice, and help in covering court costs to those who cannot raise the necessary funds to hire an attorney, but only when it is deemed that there is a reasonable chance of success.

India

Article 22 of the Constitution of India states that "No person who is arrested shall be detained in custody without being informed, as soon as may be, of the grounds for such arrest nor shall he be denied the right to consult, and to be defended by, a legal practitioner of his choice." In 2011, the Supreme Court of India ruled that a court could not decide a case without a lawyer present for the defendant, and mandated that a court must appoint a lawyer when the defendant cannot afford one. Public legal assistance is provided through the National Legal Services Authority and state-level legal services organizations. Courts appoint legal aid lawyers in both civil and criminal cases.