Background
Twenty-four Hungarian applicants — along with one applicant later struck from the list due to an administrative error — lodged an application with the European Court of Human Rights on 6 March 2025, complaining that civil proceedings in Hungary had lasted an unreasonably long time. The proceedings had commenced on 13 July 2000 and remained pending at the time the application was filed, giving a total duration of more than 24 years and 10 months at a single level of jurisdiction.
The applicants were represented by Mr B. Háromszéki, a lawyer based in Győr. The Hungarian Government was given notice of the application and the case was assigned to the Court’s Second Section, sitting as a Committee of three judges.
One applicant, Ms Imréné Révész, had been included on the applicant list due to an administrative error. The Court accordingly decided to strike the application from its list with respect to her under Article 37 § 1(c) of the Convention, finding no special circumstances requiring continued examination of her case.
The Court’s Holding
The Committee unanimously held that Hungary had violated Article 6 § 1 of the Convention, which guarantees everyone the right to a hearing within a reasonable time in the determination of their civil rights and obligations. Applying the established criteria — complexity of the case, the conduct of the parties and relevant authorities, and what was at stake for the applicants — the Court found no fact or argument capable of justifying the overall duration of the proceedings at the national level.
The Court relied on its prior findings in the leading cases of Gazsó v. Hungary (no. 48322/12, 16 July 2015) and Csatári and Others v. Hungary (no. 18514/24, 20 May 2025), in which it had already identified a systemic violation in respect of similar issues. The present case was treated as a repetitive case disclosing the same structural problem of excessive civil-proceedings duration in Hungary.
Under Article 41, the Court awarded each of the remaining applicants €200 in just satisfaction for pecuniary and non-pecuniary damage and costs and expenses, to be paid by Hungary within three months, with default interest thereafter at the European Central Bank’s marginal lending rate plus three percentage points.
Key Takeaways
- Civil proceedings initiated in Hungary on 13 July 2000 that remained pending for over 24 years and 10 months at a single level of jurisdiction constituted a breach of the “reasonable time” requirement under Article 6 § 1 of the Convention.
- The Court treated this as a repetitive case consistent with its earlier pilot and leading judgments against Hungary (Gazsó and Csatári and Others), confirming an ongoing structural problem with the length of civil proceedings in the Hungarian justice system.
- One applicant (Ms Imréné Révész) was struck from the list due to an administrative error in her inclusion, illustrating the Court’s practice of correcting procedural irregularities at the outset under Article 37 § 1(c).
- Just satisfaction was set at a modest €200 per applicant, in line with the Court’s established tariff for repetitive Hungarian length-of-proceedings cases.
Why It Matters
This judgment reinforces the Court’s consistent line of authority holding Hungary accountable for systemic delays in its civil court system. With proceedings stretching beyond a quarter-century at a single level of jurisdiction, the case exemplifies the kind of structural failing the Court has repeatedly flagged in its leading judgments against Hungary, and signals that such delays will continue to attract findings of violation regardless of any particular complexity or circumstances of the individual dispute.
For practitioners, the decision is a reminder that the “reasonable time” guarantee under Article 6 § 1 is not merely aspirational: states bear an affirmative obligation to organize their judicial systems so that cases are resolved within a reasonable period, and a failure to do so will expose them to findings of violation and orders to pay just satisfaction to affected litigants.