Whether the appellant was entitled to the appointment of ex officio counsel in the appeal proceedings.
No. The appeal case was considered simple, the appellant was not in a mandatory-defence situation, and his interests could be safeguarded without appointed counsel.
Under Art. 132 CPP, appointed counsel is justified only where defence is mandatory or where the accused lacks means and legal assistance is necessary to protect his interests. Here, the factual and legal issues were not difficult, the appellant had already presented a detailed and understandable appeal, and no special circumstance made a lawyer indispensable.