For the purposes of Article 51 the concept of 'deprivation of liberty' may take numerous forms beyond classic detention in prison or strict arrest2: therefore the question as to whether a restraint amounts to a deprivation of liberty is one of degree or intensity, rather than nature or substance3. Thus in deciding whether a person has been deprived of his liberty, several factors, including the type, duration, effects and manner of implementation of the relevant measure4, fall to be considered in the light of the concrete situation and circumstances of the individual
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