Background
Eight applicants complained about the length of criminal proceedings in Hungary. The proceedings ranged from more than four years to more than fourteen years, with several still pending when the European Court of Human Rights considered the applications. The Court joined the applications because they raised similar issues.
Seven applicants also complained that Hungarian law provided no effective domestic remedy for the excessive duration of their criminal cases. The Court gave the Hungarian Government notice of the applications.
The Court’s Holding
The Court unanimously held that the criminal proceedings had exceeded the “reasonable time” requirement in Article 6 § 1 of the Convention. Applying its established criteria—case complexity, the parties’ conduct, the authorities’ conduct, and what was at stake—it found no fact or argument justifying the overall length of the proceedings.
The Court also held that the additional Article 13 complaints disclosed violations of the Convention under its well-established case-law. It awarded the applicants between €2,300 and €9,100, plus any applicable tax, and ordered payment within three months; default interest would accrue thereafter.
Key Takeaways
- Criminal proceedings lasting more than four years, and in some cases more than ten or fourteen years, breached Article 6 § 1 on the facts before the Court.
- The Court found that the applicants who raised the issue lacked an effective domestic remedy for excessive criminal-proceeding delays.
- Hungary must pay the individual just-satisfaction awards within three months, subject to default interest.
Why It Matters
The judgment applies the Court’s settled approach to persistent delay in Hungarian criminal proceedings. It reinforces that the State must organize its criminal justice system so that cases are resolved within a reasonable time.
It also underscores that a Convention-compliant system requires an effective domestic remedy for undue delay, not merely a later finding that proceedings lasted too long.