Need for a specific warning
|Decision on Assignment of Counsel - 20.10.2006||
The Appeals chamber considered that, before restricting the accused’s right to self-representation, the Trial Chamber must issue an explicit warning specifically directed to the accused in the form of an oral or written statement. It held:
a warning with regard to possible assignment of counsel needs to be explicit, in the form of an oral or written statement to an accused explaining the disruptive behaviour and that, if it persists, the consequence will be restriction on the accused’s right to self-representation.
 Decision, para. 26.