TODOROV v. BULGARIA - 19552/05 (Judgment (Merits and Just Satisfaction) : Court (Fifth Section Committee)) French Text [2016] ECHR 647 (12 July 2016)

TODOROV v. BULGARIA - 19552/05 (Judgment (Merits and Just Satisfaction) : Court (Fifth Section Committee)) French Text [2016] ECHR 647 (12 July 2016)

The Court found that the Bulgarian system, which allows for the recovery of legal aid costs from convicted persons unless they lack means, does not violate Article 6 §§ 1 and 3(c) of the Convention, as the applicant did not demonstrate indigence and the system did not affect the fairness of the proceedings.

Source-derived case information.

Citation
[2016] ECHR 647
Parties
Applicant: Iliyan Spirov Todorov; Respondent: Republic of Bulgaria
Jurisdiction
European Union
Procedural Posture
Application Under Article 34 ECHR / Judgment (merits and Just Satisfaction)
Outcome
No violation of Article 6 §§ 1 and 3(c) of the Convention; application declared admissible.
Legal Topics
Right to Free Legal Assistance, Costs of Legal Representation, Article 6 ECHR, Access to Justice
Human Rights Law Criminal Procedure Right to Free Legal Assistance Costs of Legal Representation Article 6 ECHR Access to Justice

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Parties

Iliyan Spirov Todorov

Applicant

Republic of Bulgaria

Respondent

Procedural Posture

Application Under Article 34 ECHR / Judgment (merits and Just Satisfaction)

  1. 1 Whether requiring a convicted person to reimburse the costs of court-appointed counsel violates Article 6 §§ 1 and 3(c) of the Convention

Ratio Decidendi

The Court found that the Bulgarian system, which allows for the recovery of legal aid costs from convicted persons unless they lack means, does not violate Article 6 §§ 1 and 3(c) of the Convention, as the applicant did not demonstrate indigence and the system did not affect the fairness of the proceedings.

Court Disposition

No violation of Article 6 §§ 1 and 3(c) of the Convention; application declared admissible.