In "Director of Public Prosecutions v. Labavarde and Anor", Neerunjun C.J. said that article 11(1) of the Universal Declaration of Human Rights and article 6(2) of the Convention for the Protection of Human Rights and Fundamental Freedoms would be infringed if "the whole burden is . . . cast on the defence by the creation of a presumption of guilt on the mere preferment of the criminal charge".[7][8]