As the primary means by which the rule of law is protected in the European Convention on Human Rights, Article 61 is of fundamental importance within the scheme of the Convention2. Within its scope of application, namely proceedings which determine a person's civil rights and obligations or any criminal charge against him3, Article 6 provides for a number of core express or implied guarantees including a right of access to court and a right to a hearing which is fair, public and conducted within a reasonable period before an independent and impartial tribunal
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