Background
Rudolf Handzlík and Milan Šuster lodged separate applications against Slovakia, alleging that criminal proceedings involving them had lasted too long. The Court joined the applications because they raised the same issue under Article 6 § 1 of the European Convention on Human Rights.
According to the appended table, Handzlík’s proceedings had lasted more than 25 years and two months and were still pending, while Šuster’s lasted approximately 15 years and eight months. The table recorded no domestic award for Handzlík and a domestic award of EUR 5,000 for Šuster.
The Court’s Holding
The Court unanimously declared both applications admissible and held that Slovakia had violated Article 6 § 1. Applying the established criteria of the case’s complexity, the conduct of the applicants and authorities, and what was at stake, it found no fact or argument capable of justifying the overall duration of the proceedings. Their length was therefore excessive and failed to satisfy the Convention’s “reasonable time” requirement.
Under Article 41, the Court awarded Handzlík EUR 13,700 and Šuster EUR 11,900 for non-pecuniary damage. It also awarded EUR 250 for costs and expenses in each application, plus any applicable tax. Slovakia must pay within three months; thereafter, simple interest accrues at the European Central Bank’s marginal lending rate plus three percentage points.
Key Takeaways
- Criminal proceedings lasting more than 25 years in Handzlík’s case and approximately 15 years and eight months in Šuster’s case breached Article 6 § 1.
- The Court found nothing in the submitted materials that justified the proceedings’ overall duration.
- The Court awarded compensation separately for non-pecuniary damage and for costs and expenses.
Why It Matters
The judgment reaffirms that States must organize criminal proceedings so that cases are resolved within a reasonable time. In assessing delay, the Court considers the proceedings’ complexity, the parties’ and authorities’ conduct, and what was at stake for the applicant.
It also illustrates the Court’s continued reliance on its established Slovak excessive-delay case law, including Pavlík v. Slovakia, when materially similar proceedings remain unresolved for many years.