Background
The eight applicants were charged on 12 March 2019 with serious economic crimes. Their criminal investigation remained pending when the European Court delivered its judgment, more than seven years later.
The Slovak Constitutional Court had dismissed their constitutional complaints in 2022 and 2023 as manifestly ill-founded, citing in particular the investigation’s complexity. Before Strasbourg, the applicants complained that the investigation had exceeded the reasonable-time requirement in Article 6 § 1.
The Court’s Holding
The Court joined the applications, rejected the Government’s objection that the applicants should have filed fresh constitutional complaints after the Constitutional Court’s decisions, and declared the Article 6 § 1 complaints admissible.
Applying its established reasonable-time criteria, the Court found that neither the investigation’s complexity nor any other material before it justified its overall duration. The pending investigation was excessive and breached Article 6 § 1. The Court awarded each applicant €3,600, plus any applicable tax, within three months.
Key Takeaways
- A criminal investigation pending for more than seven years failed the Convention’s reasonable-time requirement in these circumstances.
- Its complexity did not justify the overall delay.
- The Court rejected the Government’s non-exhaustion objection based on the absence of fresh constitutional complaints.
Why It Matters
The judgment reaffirms that Slovak authorities must progress criminal investigations within a reasonable time, even where the allegations involve serious economic crime and the investigation is complex.
It also follows the Court’s approach that applicants in this procedural position were not required to lodge a further constitutional complaint before seeking Strasbourg review.