Background
Seventy-eight applicants complained under Article 6 § 1 of the European Convention on Human Rights about the length of civil proceedings in Hungary. For the 76 applicants whose complaints reached the merits, the proceedings began on 17 September 2014, remained pending, had lasted more than ten years and ten months, and had proceeded at one level of jurisdiction.
Two additional applicants, Józsefné Lőrincz and Gábor Szarka Kovács, had not been parties to the domestic proceedings. The Court therefore considered their complaints separately from those of the 76 applicants listed in the appendix.
The Court’s Holding
The Court unanimously declared the complaints of Józsefné Lőrincz and Gábor Szarka Kovács inadmissible as incompatible ratione personae because they were not parties to the proceedings at issue. It declared the remainder of the application admissible.
Applying the criteria of complexity, the applicants’ conduct, the authorities’ conduct, and what was at stake, the Court found no fact or argument capable of justifying the overall duration. It held that the excessive length of the proceedings breached Article 6 § 1’s reasonable-time requirement and awarded each of the 76 remaining applicants €200 for pecuniary and non-pecuniary damage and costs and expenses, plus any chargeable tax.
Key Takeaways
- Civil proceedings lasting more than ten years and ten months at a single level of jurisdiction failed to satisfy Article 6 § 1’s reasonable-time requirement.
- Only parties to the underlying domestic proceedings could pursue the delay complaint; the two non-parties’ complaints were inadmissible ratione personae.
- Hungary must pay each of the 76 successful applicants €200 within three months, with default interest thereafter at the European Central Bank’s marginal lending rate plus three percentage points.
Why It Matters
The judgment reinforces the Court’s established position that Hungary must ensure civil disputes are resolved within a reasonable time. Even where many applicants challenge the same prolonged proceeding, each must independently satisfy the Convention’s victim-status requirements.