Lexploria

AS TO THE ADMISSIBILITY OF

Application No. 17951/91

by H. B.

against Switzerland

The European Commission of Human Rights (Second Chamber) sitting

in private on 5 April 1995, the following members being present:

Mr. H. DANELIUS, President

Mrs. G.H. THUNE

MM. G. JÖRUNDSSON

S. TRECHSEL

H.G. SCHERMERS

F. MARTINEZ

L. LOUCAIDES

J.-C. GEUS

M.A. NOWICKI

I. CABRAL BARRETO

J. MUCHA

D. SVÁBY

Mr. K. ROGGE, Secretary to the Chamber

Having regard to Article 25 of the Convention for the Protection

of Human Rights and Fundamental Freedoms;

Having regard to the application introduced on 16 January 1991

by H. B. against Switzerland and registered on 19 March 1991 under file

No. 17951/91;

Having regard to :

- the reports provided for in Rule 47 of the Rules of Procedure of

the Commission;

- the observations submitted by the respondent Government on

16 April 1993 and the observations in reply submitted by the

applicant on 9 July 1993;

Having deliberated;

Decides as follows:

THE FACTS

The facts of the case, as submitted by the parties, may be

summarised as follows.

A. Particular circumstances of the case

The applicant, a German citizen born in 1940, is a businessman

residing in Engelberg in Switzerland. Before the Commission he is

represented by Mr. H.P. Derksen, a lawyer practising in Zurich.

I.

Upon establishing his residence in the Canton of Obwalden in 1979

the applicant entered into an agreement with the Obwalden Cantonal Tax

Administration according to which he would pay cantonal taxes in the

amount of at least 35,000 SFr per year.

In 1981/1982 the applicant's income was assessed as amounting to

180,000 SFr for the years 1980 and 1981/82.

In 1982 the Federal Tax Administration audited the accounts of

the C. company. It transpired that upon instruction of the Foreign

Ministry of Poland, the C. company had commissioned Polish workers for

building sites in Libya and that in 1980, it had paid the applicant

735,845 SFr for commission services.

In 1983 the applicant submitted a new tax declaration wherein he

referred, in addition to the previous 180,000 SFr, to remunerations

obtained from the C. company.

II.

Upon repeated insistence of the Federal Tax Administration the

Obwalden Cantonal Tax Commission introduced evasion proceedings

(Hinterziehungsverfahren) against the applicant.

On 19 August 1986 the Cantonal Tax Commission imposed on the

applicant a supplementary tax (Nachsteuer) of 172,328.15 SFr for the

years 1980-1982, as well as a fine (Busse) of 413,587.40 SFr on account

of tax evasion (Steuerhinterziehung). This fine was imposed on the

basis of Section 129 para. 1 (b) of the Federal Decree on the

Imposition of a Direct Federal Tax of 9 December 1940 (Bundesratsbe-

schluss über die Erhebung der direkten Bundessteuer; see below,

Relevant domestic law and practice).

The Cantonal Tax Commission based its decision on the facts as

they resulted from the Federal Tax Administration's documents on the

C. company and from the applicant's subsequent new tax declaration

submitted in 1983.

In its decision the Cantonal Tax Commission stated inter alia

that "by failing to declare the large-scale payments and allowances of

the C. company in 1980 in his tax declaration for the fiscal years

1981/1982, (the applicant) committed tax evasion" ("Indem

Beschwerdeführer> in seiner Steuererklärung für die Steuerjahre 1981/82

die umfangreichen Leistungen und Entschädigungen der C. AG im Jahre

1980 nicht deklariert hat, beging er eine Steuerhinterziehung").

III.

On 19 September 1986 the applicant complained against this order

to the Obwalden Cantonal Tax Appeals Commission (Steuerrekurs-

kommission) which then fixed an oral hearing for 19 February 1987. At

short notice the hearing was postponed to 23 February 1987. At this

hearing the applicant was prevented from attending, though his lawyer

was present.

On 23 February 1987 the Tax Appeals Commission dismissed the

applicant's complaint. The Tax Appeals Commission found inter alia

that the fine previously imposed by the Tax Commission on the whole was

within the framework (Rahmen) laid down in a Circular (Kreisschreiben)

of the Federal Tax Administration of 28 March 1958; in fact the

applicant's fine lay slightly below the normal amount (see below,

Relevant domestic law and practice). The Tax Appeals Commission

further relied on Section 129 para. 1 (b) of the Federal Tax Decree and

found no mitigating circumstances.

IV.

On 23 April 1987 the applicant filed an administrative law appeal

(Verwaltungsgerichtsbeschwerde) with the Federal Court (Bundesgericht).

Therein he complained inter alia under Article 6 para. 3 (a) of the

Convention that he had not promptly been informed in detail about the

charges raised against him. He also complained that he had not been

able personally to participate in the proceedings, in particular at the

oral hearing of 23 February 1987. The applicant further complained

that the use of the Circular breached his right to an independent

tribunal under Article 6 para. 1 of the Convention. There was also a

violation of Article 7 of the Convention.

On 8 July 1988 the Federal Court (Bundesgericht) gave its

judgment. According to the operative part, the administrative law

appeal was upheld for the reasons given in the considerations (im Sinne

der Erwägungen) and the case referred back to the Tax Appeals

Commission with the directive that it should question the applicant

personally and determine the supplementary tax and the fine for the

years 1980 until 1982.

In its considerations the Court first dealt with the tax period

of 1980. In the Court's opinion, the Tax Appeals Commission had

correctly assumed that the applicant had received commission services

amounting to SFr 588,675. The tax assessment concerning a further

amount of SFr 180,000 obtained by the applicant had become final. It

was also established that the applicant had committed the offence of

tax evasion in 1980 with intent. On the other hand, the Tax Appeals

Commission had not sufficiently ascertained the applicant's personal

circumstances which were relevant when determining the severity of the

punishment (Strafzumessung). As to the applicant's absence at the

hearing on 23 February 1987, the Federal Court found that he could not

be blamed for this given that the hearing had been fixed at short

notice.

In respect of the tax period 1981/1982, the Federal Court agreed

with the Tax Appeals Commission's assessment of the commission which

the applicant had received, and found that for this period the

applicant's taxable income had amounted to SFr 470,600. On the other

hand, when finding that the applicant had committed tax evasion with

intent, the Tax Appeals Commission had incorrectly relied on its

conclusion for the tax period of 1980. In this respect the

determination of facts was faulty (mangelhaft), and the Federal Court

instructed the Tax Appeals Commission to hear the applicant personally

in order to determine his culpability.

The Federal Court did not object to the use of the guidelines

laid down in the Circular of 28 March 1958. It found that the tax

authorities could derogate from the Circular and that the latter did

not release the authorities from the obligation to examine

independently all the circumstances of the case (Pflicht, die gesamten

Umstände des Einzelfalles in eigener Verantwortung zu prüfen).

V.

Proceedings were then resumed before the Cantonal Tax Appeals

Commission. On 25 April 1989 the Tax Appeals Commission conducted a

hearing at which the applicant was questioned as to his personal

circumstances with a view to fixing the fine for the tax evasion in

1980, and as to the facts of the case concerning the alleged tax

evasion in 1981/1982. The hearing was not public.

On 7 November 1989 the Tax Appeals Commission reduced the

supplementary tax imposed on the applicant to SFr 103,648.15, and the

fine to SFr 109,659.10. The applicant's request for a complete

reconsideration of his case was rejected on the ground that the Tax

Appeals Commission was bound by the facts to the extent to which they

had been established with binding effect by the Federal Court under

Section 105 para. 2 of the Federal Judiciary Act. Thus the cantonal

authorities could only examine the issues left open by the Federal

Court. In respect of the issues decided with binding effect by the

Federal Court, the applicant had failed to challenge that Court's

decision by requesting the reopening (Revision) of the Federal Court's

proceedings.

VI.

On 9 January 1990 the applicant again filed an administrative law

appeal with the Federal Court. Therein he reiterated his complaint

that he had not been informed promptly and in detail of the acts with

which he had been charged. Moreover, the investigations of the tax

authorities were incomplete, and the applicant was refused the right

to participate in the establishment of the facts. The applicant

further complained that his punishment was not in accordance with the

law, and that the use of the Circular was incompatible with judicial

independence. Finally, the applicant complained that he had not had

a public hearing in these proceedings.

On 12 June 1990 the Federal Court dismissed the administrative

law appeal. The decision was served on the applicant on 20 July 1990.

The Court found that it was prevented from dealing with the alleged

deficiencies of the previous proceedings. It noted that in its

decision of 8 July 1988 it had confirmed the offence of tax evasion

with intent for the year 1980, and the objective elements relating to

the period 1981/1982. The Court dismissed the applicant's complaint

under Article 7 of the Convention, finding that the use of a Circular

was admissible. According to general rules for the determination of

punishment (allgemeine Strafzumessungsregeln) the authorities, when

fixing the fine, had to consider the further personal circumstances of

the accused insofar as they related to his culpability.

Relevant domestic law and practice

I.

According to Section 106 of the Swiss Penal Code (Strafgesetz-

buch) the maximum amount for a fine is SFr 5,000, unless the law

provides otherwise. According to Section 333 of the Penal Code, its

general provisions also apply to offences regulated in other Federal

laws, unless the latter provide otherwise.

Section 129 para. 1 (b) of the Federal Decree on the Imposition

of a Direct Federal Tax (Bundesratsbeschluss über die Erhebung der

direkten Bundessteuer) of 9 December 1940 provides that the offence of

tax evasion "is subject to a fine of up to four times the fraudulently

concealed tax amount" ("unterliegt einer Busse bis zum Vierfachen des

entzogenen Steuerbetrages").

Section 71 of the Federal Decree states, insofar as relevant:

:

"Professional secrecy

1. Members and civil servants of the authorities of the

Federation, the Cantons and the communities and members of the

Cantonal Tax Appeals Commission responsible for the Direct

Federal Tax must observe secrecy in respect of facts of which

they learn when assessing a taxpayer and in respect of the

authorities' proceedings ...

2. Breaches of professional secrecy ... shall be punished ..."

"Schweigepflicht

1. Die Mitglieder und Beamten der für die Direkte Bundessteuer

zuständigen Behörden des Bundes, der Kantone und der Gemeinden

und die Mitglieder der kantonalen Rekurskommissionen haben über

Tatsachen, die ihnen bei der Veranlagung eines Steuerpflichtigen

bekannt werden, und über die Verhandlungen in den Behörden

Stillschweigen zu beobachten ...

2. Verletzungen der Schweigepflicht ... werden ... geahndet

..."

II.

According to the Circular (Kreisschreiben) of the Federal Tax

Administration of 28 March 1958, subsequently replaced by a Circular

of 9 December 1987, "the tax punishment must be determined within the

statutory framework of punishment ... according to objective and

subjective criteria" (innerhalb des gesetzlichen Strafrahmens ... ist

die Steuerstrafe nach objektiven und subjektiven Gesichtspunkten zu

bemessen). The objective severity of the offence is determined on the

basis of the relation of the amount withheld to the tax amount due.

The Circular further states that its principles apply to the normal

case of offences committed with intent.

COMPLAINTS

The applicant complains that contrary to Article 6 para. 1 of the

Convention he was not heard by an independent tribunal in the above

proceedings. Thus, the Tax Appeals Commission, when fixing his fine,

applied a Circular issued by the Federal Tax Administration.

The applicant furthermore complains under Article 6 para. 1 of

the Convention that the oral hearing on 23 February 1987 was held in

his absence.

Under Article 6 para. 1 of the Convention the applicant complains

that the proceedings were not conducted in public.

The applicant complains that the incomplete establishment of the

facts violated his right to the presumption of innocence under

Article 6 para. 2 of the Convention.

Under Article 6 para. 3 (a) of the Convention the applicant

complains that he was not informed promptly and in detail of the acts

with which he was charged.

Finally, the applicant complains under Article 7 of the

Convention that his punishment was not in accordance with the law.

Thus, the fine was fixed on the basis of the Circular of 28 March 1958.

Moreover, although the act qualifies under Swiss law as a misdemeanour

(Ãœbertretung) the fine exceeded the maximum envisaged by Sections 106

and 333 of the Swiss Penal Code.

PROCEEDINGS BEFORE THE COMMISSION

The application was introduced on 16 January 1991 and registered

on 19 March 1991.

On 8 January 1993 the Commission (Second Chamber) decided to

communicate the application to the respondent Government, pursuant to

Rule 48 para. 2 (b) of the Rules of Procedure, and invite them to

submit written observations on the admissibility and merits in respect

of the complaints under Article 6 para. 1 and Article 7 of the

Convention.

The Government's written observations were submitted on

16 April 1993, the applicant's observations in reply on 9 July 1993.

THE LAW

1. The applicant complains that contrary to Article 6 para. 1

(Art. 6-1) of the Convention he was not heard by an independent

tribunal in the above proceedings. Thus, the Tax Appeals Commission,

when fixing his fine, applied a Circular issued by the Federal Tax

Administration.

Article 6 para. 1 (Art. 6-1) of the Convention states, insofar

as relevant for the application:

"In the determination of his civil rights and obligations ...

everyone is entitled to a fair and public hearing ... by an

independent and impartial tribunal ..."

The Government submit that the authorities, when determining a

fine, will act duty-bound within a margin of appreciation. The Federal

Tax Administration cannot issue orders to the tax authorities. Its

Circular, when referring to the "normal" fine calculated on the basis

of the amount withheld, aims at harmonising fines by introducing

objective criteria. The Circular constitutes a first step towards

determining the objective severity of the offence. It also does not

concern the subjective side of the offence, the authorities being

called upon to determine the culpability of the person concerned.

In the applicant's submission, it contradicts the principle of

the independence of the judiciary that the latter should consider

guidelines (Richtlinien) prepared by the tax administration. According

to the Circular, the higher the amount of taxes withheld, the higher

the multiplicator will be to determine the fine.

The Commission recalls that the independence of a "tribunal"

within the meaning of Article 6 para. 1 (Art. 6-1) of the Convention

requires in particular that the body concerned must be independent of

the executive in its functions and as an institution (see Eur. Court

H.R., Campbell and Fell judgment of 28 June 1984, Series A no. 80,

p. 39 et seq., para. 78).

It is true that in the present case the domestic authorities,

when determining the applicant's fine, referred to a Circular issued

by the Federal Tax Administration.

The Commission nevertheless notes the Federal Court's decision

of 8 July 1988 according to which the Circular was not binding, in that

the tax authorities could derogate from it and were obliged

independently to examine all circumstances of the case.

The Commission finds no indication that the Tax Appeals

Commission regarded itself bound by the Circular. Thus, in its

decision of 23 February 1987 it referred to the Circular as one of

various elements. Indeed, after hearing the applicant on 25 April 1989

it reduced in its decision of 7 November 1989 the supplementary tax and

the fine imposed on the applicant.

The Commission thus does not find that the domestic courts, when

determining the applicant's fine, were subject to instructions by the

administration which could have called in question their independence

contrary to Article 6 para. 1 (Art. 6-1) of the Convention.

This part of the application is therefore manifestly ill-founded

within the meaning of Article 27 para. 2 (Art. 27-2) of the Convention.

2. The applicant complains under Article 6 para. 1 (Art. 6-1) of the

Convention that the oral hearing on 23 February 1987 before the Tax

Appeals Commission was held in his absence. Thus, he could not

participate in the establishment of the facts.

The Government submit that the applicant has not complied with

Article 26 (Art. 26) of the Convention in that he did not file his

application within six months after the Federal Court's decision of

8 July 1988. This decision referred the case back to the Tax Appeals

Commission only to the extent that the fine had to be determined, but

not in respect of the evaded tax. In any event, at the hearing of

23 February 1987 before the Tax Appeals Commission, at which the

applicant was represented by a lawyer, no witness and no new evidence

were heard.

The applicant submits that he has complied with the six months'

rule. In his administrative law appeal of 23 April 1987 he expressly

requested to be heard personally. He also introduced the present

application within six months after the Federal Court had given its

final decision on 12 June 1990. That Court's decision of 8 July 1988

was not definitive in that it referred the case back to the Tax Appeals

Commission for renewed examination.

The Commission recalls that, under Article 26 (Art. 26) of the

Convention, it may only examine a case "within a period of six months

from the date on which the final decision was taken".

In the present case, the applicant was absent at an oral hearing

before the Tax Appeals Commission on 23 February 1987, though he could

not be blamed therefor. He raised this complaint in his administrative

law appeal of 23 April 1987 to the Federal Court. The latter partly

upheld the applicant's administrative law appeal on 8 July 1988. The

Tax Appeals Commission then conducted an oral hearing in the

applicant's presence on 25 April 1989.

The Commission has examined the Federal Court's decision of

8 July 1988. On the one hand, the Court regarded it as established

that in the tax period of 1980 the applicant had received a commission

amounting to SFr 588,675 and that the assessment of a further amount

of SFr 180,000 become final. In respect of the tax period of 1981/82

it was established that the applicant's taxable income had amounted to

SFr 470,600.

On the other hand, the Court found that the Tax Appeals

Commission had not sufficiently examined the applicant's personal

circumstances which were relevant for determining the severity of the

punishment for the tax period of 1980. In respect of the tax period

of 1981/82 the Federal Court instructed the Tax Appeals Commission to

hear the applicant in order to determine his culpability.

Thus, the second set of proceedings conducted before the Tax

Appeals Commission were limited to the issues set out by the Federal

Court in its decision of 8 July 1988. In respect of these issues the

applicant had an oral hearing before the Tax Appeals Commission on

25 April 1989.

In respect of the other issues, the Federal Court's decision of

8 July 1988 was therefore final. Insofar as the applicant complains

that he did not have an oral hearing during these proceedings, he

failed to file this complaint before the Commission within six months

as from 8 July 1988. He has therefore not complied with the

requirements of Article 26 (Art. 26) of the Convention.

This part of the application must therefore be rejected according

to Article 27 para. 3 (Art. 27-3) of the Convention.

3. Under Article 6 para. 1 (Art. 6-1) of the Convention the

applicant complains that the proceedings were not conducted in public.

a) The Government submit that the applicant has not exhausted

domestic remedies according to Article 26 (Art. 26) of the Convention.

Thus, he failed to raise this complaint before the Tax Appeals

Commission. Moreover, he also did not raise this complaint in his

administrative law appeal of 23 April 1987 to the Federal Court and he

also failed to ask for a public hearing before that Court. Only in his

administrative law appeal of 9 January 1990 did he finally raise this

complaint.

The applicant submits that he has exhausted domestic remedies.

In its decision of 8 July 1988 the Federal Court left everything open

when it referred the case back to the Tax Appeals Commission which was

instructed to hear the applicant. In his subsequent administrative law

appeal of 9 January 1990 he expressly complained that he had not had

a public hearing, though the Court did not deal with it.

The Commission recalls that, under Article 26 (Art. 26) of the

Convention, it may only deal with a matter "after all domestic remedies

have been exhausted, according to the generally recognised rules of

international law".

The Commission has just found that the complaint about the

hearing of 23 February 1987 in the first set of the proceedings before

the Tax Appeals Commission is inadmissible as the applicant did not

comply with the requirements of Article 26 (Art. 26) of the Convention.

The second set of proceedings resumed before the Tax Appeals Commission

concerned issues set out by the Federal Court in its decision of

8 July 1988, relating to the applicant's personal circumstances which

were considered relevant for the determination of the fine. In respect

of these issues the applicant had an oral, albeit not public, hearing

before the Tax Appeals Commission on 25 April 1989.

The Commission notes that the applicant raised this complaint in

his administrative law appeal of 9 January 1990, though the Federal

Court did not deal with this complaint in its decision of 12 June 1990.

Nevertheless, it does not transpire that the applicant failed to comply

with the procedural requirements for filing the appeal.

The applicant's complaint cannot therefore be declared

inadmissible for non-exhaustion of domestic remedies within the meaning

of Article 26 (Art. 26) of the Convention.

Insofar as the Government submit that the applicant failed to

raise this complaint in the proceedings before the Tax Appeals

Commission, the Commission finds that this issue falls to be examined

together with the merits of the complaint.

b) The Government submit with reference to Section 71 of the Federal

Decree on the Imposition of a Direct Federal Tax that such proceedings

are conducted in non-public proceedings in order to protect the private

sphere of taxpayers. Article 6 para. 1 (Art. 6-1) of the Convention

has not been breached as the applicant's lawyer, who was well versed

in these matters, could have asked for a public hearing but failed to

do so.

The applicant submits that Section 71 of the Federal Decree does

not concern criminal proceedings. Tax evasion is a criminal matter

requiring a public hearing. The applicant did not invoke this

complaint before the Tax Appeals Commission in view of the Swiss

Government's interpretative declaration made at the time in respect of

Article 6 para. 1 (Art. 6-1) of the Convention.

The Commission finds that this complaint raises serious questions

of fact and law which are of such complexity that their determination

should depend on an examination of the merits. This aspect of the case

cannot, therefore, be regarded as being manifestly ill-founded within

the meaning of Article 27 para. 2 (Art. 27-2) of the Convention, and

no other ground for declaring it inadmissible has been established.

4. The applicant complains that the incomplete establishment of the

facts violated his right to the presumption of innocence under

Article 6 para. 2 (Art. 6-2) of the Convention.

According to this provision, "everyone charged with a criminal

offence shall be presumed innocent until proved guilty according to

law".

The Commission recalls that the presumption of innocence will be

violated if, without the accused's having previously been proved guilty

according to law, a judicial decision concerning him reflects an

opinion that he is guilty (Eur. Court H.R., Barberà, Messegué and

Jabardo judgment of 6 December 1988, Series A no. 146, p. 31, para. 67

et seq.).

Even assuming that the applicant has complied with the

requirements under Article 26 (Art. 26) of the Convention, he does not

substantiate his complaint that the presumption of innocence was

disregarded in the proceedings at issue. The mere criticism of the

assessment of evidence made by the Courts is not sufficient. It does

not appear from the case-file that during the proceedings the courts

anticipated the finding that the applicant had committed the acts with

which he was charged.

It follows that this part of the application is manifestly ill-

founded within the meaning of Article 27 para. 2 (Art. 27-2) of the

Convention.

5. Insofar as the applicant complains under Article 6 para. 3 (a)

(Art. 6-3-a) of the Convention that he was not informed promptly and

in detail of the acts with which he was charged, the Commission notes

that the acts with which the applicant was charged were expressly

stated in the decision of the Cantonal Tax Commission of

19 August 1986. This part of the application is, therefore, also

manifestly ill-founded within the meaning of Article 27 para. 2

(Art. 27-2) of the Convention.

6. The applicant complains under Article 7 para. 1 (Art. 7-1) of the

Convention that his punishment was not in accordance with the law.

Thus, the fine was fixed on the basis of the Circular of 28 March 1958.

Moreover, although the act qualifies under Swiss law as a misdemeanour

the fine exceeded the maximum envisaged by Sections 106 and 333 of the

Swiss Penal Code.

Article 7 para. 1 (Art. 7-1) of the Convention states:

"No one shall be held guilty of any criminal offence on

account of any act or omission which did not constitute a

criminal offence under national or international law at the time

when it was committed. Nor shall a heavier penalty be imposed

than the one that was applicable at the time the criminal offence

was committed."

The Government submit that the applicant has not exhausted

domestic remedies within the meaning of Article 26 (Art. 26) of the

Convention as he failed to raise this complaint in his appeal of

19 September 1986 to the Tax Appeals Commission. In any event the fine

imposed did not exceed the limit stated in Section 129 of the Federal

Decree on the Imposition of a Direct Federal Tax which provides for a

fine of up to four times the fraudulently concealed tax amount. The

applicant was thus aware of the fine which he risked if he committed

the offence concerned.

The Commission need not examine whether the applicant has

complied with the requirements under Article 26 (Art. 26) of the

Convention, as this complaint is in any event inadmissible for the

following reasons.

The Commission notes that the applicant's punishment was based

expressly on Section 129 of the Federal Decree on the Imposition of a

Direct Federal Tax. According to this provision, the offence of tax

evasion is subject to a fine of up to four times the fraudulently

concealed tax amount. The Swiss Penal Code in Section 333 expressly

envisages that other Federal laws may provide exceptions in respect of

its provisions on offences.

Thus, the act of which the applicant was convicted duly

constituted an offence under Swiss law, and his punishment did not

exceed the maximum penalty provided for in the relevant provisions, as

required by Article 7 para. 1 (Art. 7-1) of the Convention.

The remainder of the application is therefore manifestly ill-

founded within the meaning of Article 27 para. 2 (Art. 27-2) of the

Convention.

For these reasons, the Commission,

by a majority,

DECLARES ADMISSIBLE, without prejudging the merits of the case,

the complaint that the applicant did not have a public hearing;

and

unanimously,

DECLARES INADMISSIBLE the remainder of the application.

Secretary to the Second Chamber President of the Second Chamber

(K. ROGGE) (H. DANELIUS)

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H.B. v. SWITZERLAND

H.B. v. SWITZERLAND

LEXI