337. How a 'reasonable time' is calculated.

Although Article 61 refers to a hearing 'within a reasonable time'2, the relevant period in civil cases starts at the commencement of proceedings3, taking into account also any preliminary phase where a litigant is required to exhaust extra-judicial remedies4 (though not any period of negotiation5), and ends at the final determination of the dispute, including any assessment of damages6, costs award7