Background
Four applicants from Hungary brought complaints to the Court concerning the unreasonable length of criminal proceedings against them. The proceedings varied substantially: one lasted approximately 4 years and 8 months at a single level of jurisdiction, while another spanned over 13 years across three levels. All applicants were represented by Hungarian attorneys and sought relief for violations of their Convention rights.
The applicants principally complained that the length of their criminal proceedings breached Article 6 § 1 of the Convention, which guarantees the right to a fair trial within a reasonable time. Several applicants additionally raised complaints concerning the lack of effective domestic remedies available to address such excessive delays, invoking Article 13 of the Convention.
The Court’s Holding
The Court unanimously found violations of Article 6 § 1, holding that the length of the criminal proceedings against the applicants was excessive and failed to meet the “reasonable time” requirement. In assessing reasonableness, the Court applied its established three-part test: the complexity of the case, the conduct of the applicants and relevant authorities, and what was at stake for the applicants. The Court examined all material submitted and found no facts or arguments capable of justifying the overall length of the proceedings at the national level.
The Court also found violations of the Convention regarding other complaints raised by some applicants, including Article 13 (lack of effective remedy in domestic law). The Court relied on its well-established case-law and prior findings in the leading case Barta and Drajkó v. Hungary (2013), which had already addressed similar issues in Hungary.
Under Article 41 of the Convention, the Court awarded just satisfaction to the applicants, ranging from €3,300 to €5,500 per applicant for pecuniary and non-pecuniary damage and costs and expenses. Hungary was ordered to pay these amounts within three months, with simple interest accruing thereafter at the European Central Bank’s marginal lending rate plus three percentage points.
Key Takeaways
- Criminal proceedings lasting 4–13+ years violate the “reasonable time” guarantee under Article 6 § 1 of the Convention when no justifying circumstances exist.
- Hungary’s failure to provide effective domestic remedies for excessive procedural delays constitutes a separate violation of Article 13 of the Convention.
- The Court applied consistent criteria for assessing procedural length: case complexity, party conduct, and stakes involved; absent substantial justification, prolonged proceedings are incompatible with fair trial guarantees.
- Just satisfaction awards reflect both the procedural violations and the applicants’ pecuniary and non-pecuniary harm, with interest required until payment.
Why It Matters
This judgment reinforces the Court’s established position that Hungarian criminal proceedings have systematically violated the fair trial rights of applicants through excessive delays—a pattern already documented in Barta and Drajkó (2013). The finding of dual violations under Article 6 § 1 and Article 13 signals that Hungary has failed both to conduct timely proceedings and to provide meaningful domestic remedies for affected individuals, creating structural deficiencies in its criminal justice system.
For attorneys practicing in Hungary or representing Hungarian clients, the decision confirms that excessive criminal delays are actionable at the European level and establishes benchmarks for what constitutes unreasonable length. The judgment may prompt pressure for Hungarian legislative or procedural reforms to expedite criminal cases and create effective domestic remedies, as repeated violations trigger ongoing examination by the Committee of Ministers regarding Hungary’s compliance with Convention obligations.