645. Interference must not be arbitrary.

The severe measure of disenfranchisement1 must not be resorted to lightly and the principle of proportionality requires a discernible and sufficient link between the sanction and the conduct and circumstances of the individual concerned2. However, although an independent court applying an adversarial procedure provides a strong safeguard against arbitrariness3, the removal of the right without any ad hoc judicial decision as to its individual impact does not, in itself, give rise to a violation of Article 3 of Protocol 1