This judgment in the case of *Angyal and Others v. Slovakia* concerns a systemic issue regarding the excessive length of administrative proceedings in Slovakia. The European Court of Human Rights (the Court) examined applications from a large group of individuals involved in long-standing restitution claims that have remained unresolved for over two decades. The Court found that the domestic authorities failed to provide a timely resolution, thereby violating the “reasonable time” requirement under Article 6 § 1 of the Convention. Furthermore, the Court determined that the applicants lacked an effective domestic remedy to address this delay, as the Constitutional Court of Slovakia had improperly segmented the proceedings and declined jurisdiction. Consequently, the Court ruled against Slovakia, awarding compensation to the applicants for the non-pecuniary damage suffered due to these protracted proceedings.
### Structure and Provisions
The decision follows the standard structure of a Committee-level judgment, consisting of the procedural history, the facts of the case, the legal assessment, and the final ruling on damages.
* **Joinder and Locus Standi:** The Court joined the two applications due to their identical subject matter and confirmed that the heirs of deceased applicants have the right to continue the proceedings.
* **Admissibility:** The Court rejected the Government’s objection regarding the failure to exhaust domestic remedies, specifically the argument that applicants should have used a new administrative action for acceleration. The Court held that the constitutional complaint already utilized by the applicants was sufficient for the purpose of the Convention.
* **Merits:** The Court reaffirmed its previous findings in the *Balogh and Others* line of cases, concluding that the complexity of the case and the conduct of the parties did not justify the extreme duration of the proceedings.
* **Article 13 Violation:** A significant provision is the finding of a violation of Article 13, as the Constitutional Court’s refusal to examine the overall length of the proceedings left the applicants without an effective means of redress at the national level.
### Key Provisions for Legal Practice
For legal practitioners, this decision is particularly important for three reasons:
1. **Exhaustion of Remedies:** The judgment clarifies that when a state provides multiple parallel remedies for the same grievance (e.g., constitutional complaints vs. administrative actions for acceleration), an applicant is not required to exhaust every possible avenue if one effective remedy has already been pursued.
2. **Prohibition of Segmentation:** The Court explicitly rejected the practice of national courts “segmenting” proceedings to avoid assessing the total duration of a case. It reinforces the principle that the “reasonable time” requirement must be assessed based on the *overall* length of the proceedings, from the initiation of the administrative process through to the final court resolution.
3. **Precedent and Consistency:** By citing the *Balogh and Others* judgments, the Court signals that it will maintain a strict stance against Slovakia regarding these specific restitution proceedings, making it a vital reference for any ongoing litigation involving similar administrative delays in the region.
***:** This decision is highly relevant to the context of administrative justice and the protection of property rights, themes that are of significant concern in jurisdictions undergoing complex restitution processes, including those affected by historical administrative backlogs.*
