s of Judgments and Decisions 1997-VII). In particular, in the case of Eriksen v. Norway, the Court considered that the applicant's detention was justified under both sub-paragraphs (a) and (c) of Article 5 § 1 and found that Article 5 § 3 was applicable (see Eriksen v. Norway, 27 May 1997, § 92, Reports of Judgments and Decisions 1997-III).
59. In the present case, on 6 April 2004 the applicant was convicted of theft and forgery of documents and sentenced to a term of imprisonment which he completed on 31 July 2006. During that period he was detained "after conviction by a competent court" within the meaning of Article 5 § 1 (a). At the same time, he was held in custody in connection with an unrelated set of criminal proceedings for the purpose of bringing him before the competent legal authority on suspicion of being a member of an armed criminal gang and having committed robbery, extortion, kidnapping and murder, a situation envisaged in Article 5 § 1 (c). It accordingly follows that, from 6 April 2004 to 31 July 2006, the applicant's deprivation of liberty fell within the ambit of both sub-paragraphs (a) and (c) of Article 5 § 1. Taking into account that the applicant was detained on the basis of Article 5 § 1 (c), and notwithstanding the fact that his detention was also grounded on Article 5 § 1 (a), the Court considers that this period should be taken into consideration for the purposes of Article 5 § 3. Therefore, the applicant has been continuously detained pending trial on the charges of membership of an armed criminal gang, robbery, extortion, kidnapping and murder, since he was remanded in custody on 16 September 2003 until now, that is for more than five years and nine months.
(ii) Reasonableness of the length of the period in issue
60. It is not disputed by the parties that the applicant's detention was initially warranted by reasonable suspicion that he was a member of an armed criminal gang and involved in robbery, extortion, kidnapping and murder. It remains to be ascertained whether the judicial authorities gave "relevant" and "sufficient" grounds to justify his continued detention and whether they displayed "special diligence" in the conduct of the proceedings. The inordinate length of the applicant's detention is a matter of grave concern for the Court. In these circumstances, the Russian authorities should have put forward very weighty reasons for keeping the applicant in detention for more than five years and nine months.
61. The judicial authorities relied, in addition to the reasonable suspicion against the applicant, on the risk of his absconding, reoffending or interfering with witnesses or jurors. In this respect they referred to the gravity of the charges, with particular emphasis on the charge of membership of an armed criminal gang, and the absence of permanent employment.
62. The gravity of the charges was the main factor for the assessment of the applicant's potential to abscond, reoffend or obstruct the course of justice. The Court has repeatedly held that, although the severity of the sentence faced is a relevant element in the assessment of the risk that an accused might abscond or reoffend, the need to continue the deprivation of liberty cannot be assessed from a purely abstract point of view, taking into consideration only the gravity of the offence. Nor can continuation of the detention be used to anticipate a custodial sentence (see Letellier v. France, judgment of 26 June 1991, Series A No. 207, § 51; see also Panchenko v. Russia, No. 45100/98, § 102, 8 February 2005; Goral v. Poland, No. 38654/97, § 68, 30 October 2003; and Ilijkov, cited above, § 81).
63. Another ground for the applicant's detention was his presumed membership of an organised criminal group. The Court accepts that in cases concerning organised crime the risk that a detainee if released might put pressure on witnesses or might otherw
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