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"Preparing a Case for the European Court of Human Rights"

Law Firm in Tirana: ISUFI & International AssociatesThe European Court of Human Rights is an international court based in Strasbourg. It consists of a number of judges equal to the number of member States of the Council of Europe that have ratified the Convention for the Protection of Human Rights and Fundamental Freedoms – currently forty-five.
The Court’s judges sit in their individual capacity and do not represent any State. In dealing with applications, the Court is assisted by a Registry consisting mainly of lawyers from all the member States (who are also known as legal secretaries). They are entirely independent of their country of origin and do not represent either applicants or States.

What is the European Convention on Human Rights?

The European Convention on Human Rights is an international treaty which only member States of the Council of Europe may sign. The Convention, which establishes the Court and lays down how it is to function, contains a list of the rights and guarantees which the States have undertaken to respect.

What does the Court of Human Rights do?

The Court applies the European Convention on Human Rights. Its task is to ensure that States respect the rights and guarantees set out in the Convention. It does this by examining complaints (known as “applications”) lodged by individuals or, sometimes, by States. Where it finds that a member State has violated one or more of these rights and guarantees, the Court delivers a judgment. Judgments are binding: the countries concerned are under an obligation to comply with them.

When can I apply to the European Court of Human Rights?

You may lodge an application with the Court if you consider that you have personally and directly been the victim of a violation of the rights and guarantees set out in the Convention or its Protocols. The violation must have been committed by one of the States bound by the Convention.

What rights are protected by the Convention and its protocol?

• the right to life;
• the right to a fair hearing in civil and criminal matters;
• the right to respect for private and family life;
• freedom of expression;
• freedom of thought, conscience and religion;
• the right to an effective remedy;
• the right to the peaceful enjoyment of possessions;
• and the right to vote and to stand for election

What do the Convention and its protocols prohibit?

The following, in particular, are prohibited :

• torture and inhuman or degrading treatment or punishment;
• arbitrary and unlawful detention;
• discrimination in the enjoyment of the rights and freedoms set out in the Convention;
• the expulsion by a State of its own nationals or its refusing them entry;
• the death penalty;
• and the collective expulsion of aliens.

What conditions do I have to satisfy to lodge an application?

What are the conditions relating to me personally?

• You do not need to be a national of one of States bound by the Convention. The violation you are complaining of must simply have been committed by one of those States within its “jurisdiction”, which usually means within its territory.
• You can be a private individual or a legal entity such as a company or association.
• You must have directly and personally been the victim of the violation you are alleging. You cannot make a general complaint about a law or a measure, for example because it seems unfair; nor can you complain on behalf of other people (unless they are clearly identified and you are their official representative).
Are there any procedures that must be followed beforehand in the national courts?
• Yes. You must have used all the remedies in the State concerned that might have been able to redress the situation you are complaining about (usually, this will mean an application to the appropriate court, followed by an appeal, where applicable, and even a further appeal to a higher court such as the supreme court or constitutional court, if there is one).
• It is not enough merely to make use of these remedies. In so doing, you must also have actually raised your complaints (that is, the substance of the Convention violations you are alleging).
• You have only six months from the date of the final decision at domestic level (generally speaking, the judgment of the highest court) to lodge an application. After that period your application cannot be accepted by the Court.
Against whom can I lodge an application?
• Against one or more of the States bound by the Convention which, in your opinion, has/have (through one or more acts or omissions directly affecting you) violated the European Convention on Human Rights.
• The act or omission complained of must have been by one or more public authorities in the State(s) concerned (for example, a court or an administrative authority).
• The Court cannot deal with complaints against individuals or private institutions, such as commercial companies.




What can my application be about?

• Your application must relate to one of the rights set out in the European Convention on Human Rights. Alleged violations may cover a wide range of issues, such as: torture and ill-treatment of prisoners; lawfulness of detention; shortcomings in civil or criminal trials; discrimination in the exercise of a Convention right; parental rights; respect for private life, family life, the home and correspondence; restrictions on expressing an opinion or on imparting or receiving information; freedom to take part in an assembly or demonstration; expulsion and extradition; confiscation of property; and expropriation.
• You cannot complain of a violation of any legal instrument other than the European Convention on Human Rights, such as the Universal Declaration of Human Rights or the Charter of Fundamental Rights.

How should I apply to the Court if I consider myself to be the victim of a violation of a convention?
By sending a letter to the Court giving clear details of your complaint (in which case you will receive an application form3 which must be filled out) or by filling out an application form directly. The letter and/or application form should be sent to the following address :

The Registrar
European Court of Human Rights
Council of Europe
F-67075 Strasbourg Cedex

• You may write in one of the Court’s official languages (English and French) or in an official language of one of the States that have ratified the Convention.
• If you lodge your application by fax, you must also send a copy by post.
• Do not come to Strasbourg in person to state your case orally. Your case will not be examined any more quickly and you will not receive any legal advice.
• The Registry may ask you for additional documents, information or explanations relating to your complaints.
• As soon as you have a copy of the application form, you should fill it out carefully and legibly and return it as quickly as possible. It must contain :
o a brief summary of the facts and your complaints;
o an indication of the Convention rights you think have been violated;
o the remedies you have already used;
o copies of the decisions given in your case by all the public authorities concerned (these documents will not be returned to you, so only copies should be sent);
o and your signature as the applicant, or your representative’s signature.
• If you do not wish your identity to be disclosed, you must inform the Court immediately, giving reasons. The President will determine whether your request is justified.
• At this stage of the proceedings you do not have to be represented by a lawyer. If, however, you wish to apply to the Court through a representative, you must send with the form your authority4 for him or her to act on your behalf.


 What are the main features proceedings?

• Proceedings are conducted in writing. You will be informed in writing of any decision taken by the Court. Public hearings are exceptional.
• Your case will be dealt with free of charge.
• Although you do not need to be represented by a lawyer in the first stages of the proceedings, you will need a lawyer once your application has been notified to the Government. The great majority of applications are, however, declared inadmissible without being notified to the Government.
• You will have to bear only your own costs (such as lawyers’ fees or expenses relating to research and correspondence).
• After your application has been lodged, you may apply for legal aid. Legal aid is not granted automatically, and awards are not made immediately but only at a later stage of the proceedings.
What are the main stages in the process?
• The Court must first examine whether your application is admissible. This means that the case must comply with certain requirements set out in the Convention (see “What conditions do I have to satisfy to lodge an application?” on page 3). If the conditions are not satisfied, your application will be rejected. If you have made several complaints, the Court may declare one or more of them admissible and dismiss the others.
• If your application or one of your complaints is declared inadmissible, that decision is final and cannot be reversed.
• If your application or one of your complaints is declared admissible, the Court will encourage the parties (you and the State concerned) to reach a friendly settlement. If no settlement is reached, the Court will consider the application “on the merits” – that is, it will determine whether or not there has been a violation of the Convention.

How long shall I have to wait?

• In view of the current backlog of cases, you may have to wait a year before the Court can proceed with its initial examination of your application. Some applications may be treated as urgent and dealt with as a matter of priority, particularly where the applicant is said to be in imminent physical danger
What can I hope to obtain?
If the Court finds that there has been a violation, it may award you “just satisfaction”, a sum of money in compensation for certain forms of damage. The Court may also require the State concerned to refund the expenses you have incurred in presenting your case. If the Court finds that there has been no violation, you will not have to pay any additional costs (such as those incurred by the respondent State).

Please note:

• The Court is not empowered to overrule national decisions or annul national laws.
• The Court is not responsible for the execution of its judgments. As soon as it has given judgment, responsibility passes to the Committee of Ministers of the Council of Europe, which has the task of supervising execution and ensuring that any compensation is paid.
What is the court of Human Rights not able to do for me?
• The Court does not act as a court of appeal vis-à-vis national courts; it does not rehear cases, it cannot quash, vary or revise their decisions.
• The Court will not intercede directly on your behalf with the authority you are complaining about. In exceptional circumstances the Court may, however, grant interim measures. As a matter of practice it only does so where there is a serious risk of physical harm to the applicant.
• The Court will not help you find or pay a lawyer to draw up your application.
• The Court cannot give you any information on legal provisions in force in the State against which your complaints are directed.

Applications to the Court should be sent by normal post or by fax
Address:
European Court of Human Rights
Council of Europe
67075 Strasbourg-Cedex
France

Fax: +33 (0)3 88 41 27 30


 Procedure

Complaints of violations by member states are filed in Strasbourg, and are assigned to a Section. Each complaint is first heard by a committee of three judges, which may unanimously vote to strike any complaint without further examination. Once past committee, the complaint is heard and decided by a full Chamber. Decisions of great importance may be appealed to the Grand Chamber. Any decision of the court has the character of a recommendation and is therefore executed on the sole discretion of the affected member states.
It is the role of the Committee of Ministers of the Council of Europe to supervise the execution of court judgments, though it has no formal means of using force against member countries in order to comply. However, the ultimate sanction of non-compliance is expulsion from the Council of Europe and thus becoming a 'pariah' state within Europe. Furthermore, the European Union takes a keen interest in the Convention and Court (and its jurisprudence) so would not look kindly upon any EU member state that did not fulfill its Convention obligations.

Taking a case to the European Court of Human Rights

Even though the HRA has now come into force in the UK it is still possible to make an application to the ECHR. There are three key requirements that you must meet:

1. You must be a victim of a violation of one or more of the articles of the Convention. Generally, this means you must be directly affected by a breach of the Convention. In some cases it will be enough to show you are likely to be affected by a breach or that you belong to a group of people, some of whom are likely to be affected. For example, gay men were permitted to challenge laws that criminalized gay sex even though it was unlikely that the individual applicants would ever be prosecuted because the laws were rarely enforced.

2. Before you make an application to the ECHR you must pursue any proceedings that you could take in the UK that are capable of providing you with an adequate remedy for the breach of your Convention rights. Now that the HRA is in force this will generally mean that you will have to take proceedings in the UK under the HRA. This may not be necessary, however, where it is clear that the best you could hope to achieve from taking proceedings under the HRA is a declaration of incompatibility.

3. You must make your application to the ECHR within six months of the conclusion of any court proceedings that you have taken in the UK that could have provided you with a remedy or, if there were no proceedings that it was reasonable to expect you to take, within six months of the event which gives rise to your application.
When you make an application to the ECHR you will be asked to complete one of the ECHR’s application forms. However, it is not necessary to fill out one of these forms to meet the six month rule. All you need to do is to get a letter to the court within the six months setting out:

1. Your details (name, address and nationality).
2. The country against which you are making your application.
3. The facts that have given rise to your application.
4. The article or articles of the Convention that you say have been breached.

You should send your letter to:

The Registrar
European Court of Human Rights
Council of Europe
F-67075 Strasbourg Cedex
France
Fax: 00 33 3 88 41 27 30

When it has received your letter the ECHR will send you one of its application forms to complete. If there is not enough space on the form you can set out your case in a longer document which you attach to the form. It is important that you submit your completed application form within any deadline set by the ECHR or, if no deadline is set, within a few weeks of receiving it. If you do not submit the form speedily you run the risk that the ECHR will decide that you have not met the six month deadline. If you cannot meet any deadline that is set you should contact the ECHR and try to agree an extended deadline.

Once the ECHR has acknowledged receipt of your application form it may be some time (months if not years) before you hear anything further.

At this stage the ECHR may rule your application inadmissible. The ECHR will not give reasons and there is no right of appeal. If your application is ruled inadmissible you will not be able to proceed with it.

If it is not ruled inadmissible at this stage, your application will be allocated to one of the ECHR’s four sections. A panel of seven judges from that section will deal with the case. This panel will always include the judge appointed by the United Kingdom. Very significant cases may be dealt with by the ECHR’s Grand Chamber. These cases are considered by a panel of seventeen judges. A case could be transferred to the Grand Chamber at any stage in the proceedings.

Your application will also be communicated to the Government at this stage, that is, the Government will be informed that you have made an application and will be invited to respond. You will be given an opportunity to respond to the Government’s observations and there may be further exchanges of written representations.

The ECHR will then decide whether your application is admissible. It can rule your application inadmissible if you have failed to meet one of the three requirements set out above or if the ECHR considers that it is ‘manifestly ill-founded’, in other words, that is not arguable. If the ECHR finds your application inadmissible at this stage it will give reasons, but there is no right of appeal.

If the ECHR finds your application admissible it will then go on to decide whether there has been a breach of the Convention. The ECHR usually refers to this as considering the merits of the application. At this point you have the right to put in a claim for compensation. The ECHR calls this ‘just satisfaction’. It should include a claim for legal expenses if you have incurred any. Your claim for just satisfaction should be sent to the ECHR within two months of the ECHR finding your application admissible. Both sides may make further representations before the ECHR decides on the merits of the application.

When the ECHR has made its decision on the merits of your application, you will be notified of the date on which its judgment will be made public. The judgment will be published on the ECHR’s website on that day. If the ECHR finds that there has been a breach of your rights it may award you compensation although it does not always do so on the basis that its finding that there has been a breach of your rights is enough.

Once a section of the ECHR has made a final decision on the merits of an application, either party, the Government or the Applicant, can ask to have the application referred to the Grand Chamber. This is the only form of appeal that the ECHR’s rules allow for. The Grand Chamber only rarely agrees to a referral. There is no appeal from a final decision made by the Grand Chamber.


Hearings 

The ECHR deals with most cases without holding a hearing; it reaches its decisions on the basis of written representations made by the parties. When the ECHR does decide to hold a hearing this will usually take place before the ECHR has decided on the admissibility of the application, although it may also hold a hearing after an application has been found admissible if it has not already held one.

Legal Aid

The ECHR has a system of legal aid although the payments which a lawyer receives under the scheme are very low. You can apply for legal aid once your application has been communicated to the Government. It is particularly useful to have legal aid if the ECHR holds a hearing on your case, as legal aid will pay the cost of your and your lawyer’s trip to Strasbourg. Eligibility for legal aid will depend on the Legal Services Commission accepting that you would be eligible for legal aid in this country.

If you are not eligible for legal aid, your lawyer may agree to represent you under a conditional fee agreement, that is, on the basis that they will only get paid if you win your case and get your legal costs paid by the Government. However, as very few applications to the ECHR are successful, your lawyer may be reluctant to take this risk. If you lose your case there is no possibility of you being ordered to pay the Government’s legal costs.

Getting Assistance

There are a number of human rights non-governmental organizations with substantial experience and expertise in bringing or advising on European Court applications. Practitioners might consider contacting these NGOs for advice or assistance on both the European Convention law and the procedure. Two NGOs, Liberty and the AIRE Centre, have particular experience in representing applicants before the European Court.


 Third Party Intervention

The European Court operates a well-established and important system for intervention in cases by third parties. Under Article 36 of the Convention, the Court may permit Convention states to intervene. Under Article 36(1), a state is entitled to intervene to submit written comments and/or take part in hearings where one of its nationals is an applicant. Furthermore, Article 36 also permits any person concerned (which might include a state, or an individual, or an organization) to intervene if it is considered to be in the interest of the proper administration of justice. Any time after the Court has given the respondent state notice of an application, a third party may be given permission by the Court to submit written comments or, in exceptional cases, to take part in hearings (Article 36(2), Rule 44(2) ).

Any third party seeking to intervene should write to the President of the Chamber for permission to do so within 12 weeks of notice of the application having been given to the respondent state. It is therefore suggested that a letter seeking permission to intervene should set out details about the intervener and outline the issues which the intervener proposes to address in its submissions. The written submissions are sent to the parties to the case who will be entitled to submit observations in reply. Those observations in reply will be sent to the intervener to submit any further comments.

For the Court the third party intervention process may assist in clarifying the context in which a particular policy or practice has been adopted by a Convention state.
Requests for permission to lodge third party interventions will usually be made in relation to the merits stage of proceedings. But it is also possible to be granted permission to lodge a third party intervention for the purposes of deciding admissibility.

Admissibility procedure

5. Each individual application is assigned to a Section, whose President designates a rapporteur. After a preliminary examination of the case, the rapporteur decides whether it should be dealt with by a three-member Committee or by a Chamber.
6. A Committee may decide, by unanimous vote, to declare inadmissible or strike out an application where it can do so without further examination.
7. Individual applications which are not declared inadmissible by Committees, or which are referred directly to a Chamber by the rapporteur, and State applications are examined by a Chamber. Chambers determine both admissibility and merits, in separate decisions or where appropriate together.
8. Chambers may at any time relinquish jurisdiction in favour of the Grand Chamber where a case raises a serious question of interpretation of the Convention or where there is a risk of departing from existing case-law, unless one of the parties objects to such relinquishment within one month of notification of the intention to relinquish. In the event of relinquishment the procedure followed is the same as that set out below for Chambers.
9. The first stage of the procedure is generally written, although the Chamber may decide to hold a public hearing, in which case issues arising in relation to the merits will normally also be addressed.
10. Decisions on admissibility, which are taken by majority vote, must contain reasons and be made public.

Elona FANI
Trainee Solicitor at ISUFI & International Associates

N O T E S for the guidance of persons wishing to apply to the EUROPEAN COURT OF HUMAN RIGHTS


I. WHAT CASES CAN THE COURT DEAL WITH?

1. The European Court of Human Rights is an international institution which in certain circumstances can examine complaints from persons claiming that their rights under the European Convention on Human Rights have been infringed. This Convention is an international treaty by which a large number of European States have agreed to secure certain fundamental rights. The rights guaranteed are set out in the Convention itself, and also in Protocols Nos. 1, 4, 6, 7 and 13 which only some of the States have accepted. You should read these texts and the accompanying reservations, which are all enclosed.

2. If you consider that you have personally and directly been the victim of a breach of one or more of these fundamental rights by one of the States, you may complain to the Court.

3. The Court can only deal with complaints relating to infringements of one or more of the rights set forth in the Convention and Protocols. It is not a court of appeal vis-à-vis national courts and cannot annul or alter their decisions. Nor can it intervene directly on your behalf with the authority you are complaining about.

4. The Court can only examine complaints that are directed against States which have ratified the Convention or the Protocol in question and concern events after a given date. The date varies according to the State and according to whether the complaint relates to a right set out in the Convention itself or in one of the Protocols.

5. You can only complain to the Court about matters which are the responsibility of a public authority (legislature, administrative authority, court of law, etc.) of one of these States. The Court cannot deal with complaints against private individuals or private organisations.

6. By the terms of Article 35 § 1 of the Convention, the Court can only deal with an application after all domestic remedies have been exhausted and within a period of six months from the date on which the final decision was taken. The Court will not be able to consider any application that does not satisfy these admissibility requirements.

7. It is therefore absolutely essential that before applying to the Court, you should have tried all judicial remedies in the State concerned by means of which it might have been possible to redress your grievance; failing that, you will have to show that such remedies would have been ineffective. You must accordingly have first applied to the domestic courts, up to and including the highest court with jurisdiction in the matter, where you must have raised, at least in substance, the complaints that you wish to submit subsequently to the Court.

8. When availing yourself of the appropriate remedies, you must normally comply with national rules of procedure, including time-limits. If, for instance, your appeal is dismissed because you have brought it too late or in the wrong court or have not used the proper procedure, the Court will not be able to examine your case.

9. However, if you are complaining of a court decision such as a conviction or sentence, it is not necessary to have tried to have your case reopened after going through the normal appeal procedures in the courts. Nor do you have to have made use of non-contentious remedies or seek a pardon or an amnesty. Petitions (to Parliament, the Head of State or Government, a minister or an ombudsman) are not regarded as effective remedies that you must have used.

10. After a decision of the highest competent national court or authority has been given, you have six months within which you may apply to the Court. The six-month period begins when the final court decision in the ordinary appeal process is served on you or your lawyer, not on the date of any later refusal of an application to reopen your case or of a petition for pardon or amnesty or of any other non-contentious application to an authority.

11. Time only stops running when the Court first receives from you either your first letter clearly setting out – even if only in summary form – the subject-matter of the application you may wish to lodge or a completed application form. A mere request for information is not sufficient to stop time running for the purposes of complying with the six-month time-limit.

12. Purely for information purposes, you should be aware that more than 90% of the applications examined by the Court are declared inadmissible for failure to comply with one or more of the conditions referred to above.


II. HOW TO APPLY TO THE COURT

13. The Court’s official languages are English and French but if it is easier for you, you may alternatively write to the Registry in an official language of one of the States that have ratified the Convention. During the initial stage of the proceedings you may also receive correspondence from the Court in that language.
Please note, however, that at a later stage of the proceedings, namely when the Court does not declare your application inadmissible on the basis of the file as submitted by you but decides to ask the Government to submit written comments on your complaints, all correspondence from the Court will be sent to you in English or French and you or your representative will in principle also be required to use English or French in your subsequent submissions.

14. Applications to the Court may be made only by post (not by telephone). If you send your application by e-mail or fax, you must confirm it by post. No purpose will be served by your coming to Strasbourg in person to state your case orally.

15. All correspondence relating to your complaint should be sent to the following address:

The Registrar
European Court of Human Rights
Council of Europe
F–67075 STRASBOURG CEDEX.

Please do not staple, seal with adhesive tape, or otherwise bind any correspondence or documents you send to the Court. All pages should be numbered consecutively.

16. On receipt of your first letter or the application form, the Registry of the Court will reply, telling you that a file (whose number must be mentioned in all subsequent correspondence) has been opened in your name. Subsequently, you may be asked for further information, documents or particulars of your complaints. On the other hand, the Registry cannot inform you about the law of the State against which you are making your complaint or give legal advice concerning the application and interpretation of national law.

17. It is in your interest to be diligent in your correspondence with the Registry. Any delay or failure to reply may be taken to mean that you no longer wish to pursue the examination of your case.

18. If you consider that your complaints concern one of the rights guaranteed by the Convention or one of the Protocols, and that the conditions described above are satisfied, please fill in the application form carefully and legibly and send it, together with any documents required for its examination, as soon as possible and in any case not later than six months after the date of the first communication from the Registry. If the application form and all the relevant documents are not sent before that time-limit expires, this will be taken to mean that you no longer wish to pursue the examination of your case and your file will be destroyed.

19. By the terms of Rule 47 of the Rules of Court, it is essential that in your application you:

(a) give a brief summary of the facts of which you wish to complain and the nature of your complaints;
(b) indicate which of your Convention rights you think have been infringed;
(c) state what remedies you have used;
(d) list the official decisions in your case, giving the date of each decision, the court or authority which took it, and brief details of the decision itself. Attach to your letter a full copy of these decisions. (No documents will be returned to you. It is thus in your interest to submit only copies, not the originals.)

20. Rule 45 of the Rules of Court requires the application form to be signed by you as applicant or by your representative.

21. If you do not wish your identity to be disclosed to the public, you must say so and set out the reasons for such a departure from the normal rule of public access to information in the proceedings. The Court may authorise anonymity in exceptional and duly justified cases.

22. In accordance with Rule 33 of the Rules of Court, documents deposited with the Registry by the parties or by any third parties are to be accessible to the public, unless the President decides otherwise for the reasons set out in Rule 33 § 2. It follows that as a general rule any information contained in the documents which you lodge with the Registry, including information about identified or identifiable persons, may be accessible to the public. Moreover, such information may appear in the Court’s HUDOC data base accessible via the Internet if the Court includes it in a statement of facts prepared for notification of the case to the respondent Government, a decision on admissibility or striking off, or a judgment.

23. For the purpose of lodging the initial complaint, you need not be represented by a lawyer, nor does your representative have to be a lawyer. However, when the Court decides to ask the Government to submit written comments on your complaints, you will in principle be required to be represented by a lawyer for the purpose of the ensuing proceedings. This lawyer must, in the absence of any special exemption, be an advocate authorised to practise in one of the States that have ratified the Convention and he or she must have an adequate knowledge of one of the Court’s official languages (English and French). It should be noted that from that stage onwards, the Court's correspondence to you will be in one of the official languages and your submissions must be in one of the Court's official languages, unless you have been granted leave to continue using a non-official language. If you have legal representation, the application form must be accompanied by your authority for the advocate or other representative to act on your behalf. A representative of a legal entity (company, association, etc.) or group of individuals must provide proof of his or her legal right to represent it.
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24. The Court does not grant legal aid to help you pay for a lawyer to draft your initial complaint. At a later stage of the proceedings – after a decision by the Court to communicate the application to the government concerned for written observations – you may be eligible for free legal aid if you have insufficient means to pay a lawyer’s fees and if a grant of such aid is considered necessary for the proper conduct of the case.

25. Your case will be dealt with free of charge. As the proceedings are initially in writing, there is no point in coming to the Court’s premises in person. You will automatically be informed of any decision taken by the Court.

ABOUT THE AUTHOR: Elona FANI, Trainee Solicitor at ISUFI & International Associates
ISUFI & International Associates is a part of an international legal consortium with operating presence in London, Athens, Russia, Izmir, Hungary, Varna, Vilnius, Tirana and Baku.
The law firm enjoys a leading front especially on insurance, reinsurance, state aide and competition not only in Albania but in Kosovo and Macedonia.

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Disclaimer: While every effort has been made to ensure the accuracy of this publication, it is not intended to provide legal advice as individual situations will differ and should be discussed with an expert and/or lawyer. For specific technical or legal advice on the information provided and related topics, please contact the author.

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