THIRD SECTION

DECISION

AS TO THE ADMISSIBILITY OF

Application no. 33274/96

by Gordon FOXLEY

against the United Kingdom

The European Court of Human Rights ( Third Section ) sitting on 12 October 1999 as a Chamber composed of

Mr J.-P. Costa, President , Sir Nicolas Bratza, Mr L. Loucaides, Mr P. KÅ«ris, Mrs F. Tulkens, Mr K. Jungwiert, Mrs H.S. Greve, Judges ,

with Mrs S. Dollé, Section Registrar ;

Having regard to Article 34 of the Convention for the Protection of Human Rights and Fundamental Freedoms;

Having regard to the application introduced on 14 November 1995 by Gordon Foxley against the United Kingdom and registered on 1 October 1996 under file no. 33274/96;

Having regard to the reports provided for in Rule 49 of the Rules of Court;

Having regard to the observations submitted by the respondent Government on 30 July 1998 and the observations in reply submitted by the applicant on 22 December 1998;

Having deliberated;

Decides as follows:

THE FACTS

The applicant is a British national, born in 1924. At the time of the introduction of the application the applicant was serving a prison sentence. He is represented before the Court by Mr P. Leach, a lawyer with Liberty, a civil liberties organisation based in London.

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

A. Particular circumstances of the case

On 3 April 1989 the Criminal Justice Act of 1988 (“the 1988 Act”) entered into force. Under the 1988 Act, trial courts may make confiscation orders aimed at removing assessed benefits obtained through the commission of offences of which a person has been found guilty.

On 25 June 1992 the applicant was arrested and at some unspecified point in time charged and committed for trial.

On 3 November 1993 the Snaresbrook Crown Court convicted the applicant of twelve counts of corruption committed between 11 December 1979 and 7 August 1984, when he was employed by the Ministry of Defence as an ammunition procurement officer. The court sentenced him to four years’ imprisonment under section 1 of the Prevention of Corruption Act 1906 on each of the twelve counts, to be served concurrently.

The court conducted an enquiry under the 1988 Act and found that the applicant had benefited from the commission of the offences in the amount of GBP 2,092,569.20. Pursuant to section 71 of the 1988 Act, a confiscation Order was made against him in the amount of GPB 1,503,301.80, the amount at which his realisable assets was assessed. This sum was to be paid within eighteen months. In default of payment the applicant was to be imprisoned for a further (consecutive) term of three years.

The applicant’s appeals against his conviction and sentence, and in relation to the amount and basis of calculation of the confiscation Order, were dismissed by the Court of Appeal on 6 February 1995. The applicant did not dispute before the Court of Appeal that he had realisable assets in excess of GBP 1.27 million.

On 4 December 1995 the Bow Street Magistrates’ Court issued a summons for the commitment of the applicant to custody for default in the payment of the amount due under the confiscation order. The hearing on whether the applicant should be committed to custody for non-payment of the confiscation Order was adjourned at the request of the Crown Prosecution Service (“CPS”) pending an investigation into alternative methods of recovery.

On 8 August 1996, in connection with the enforcement of the confiscation Order, Ms S.D. was appointed as Receiver to realise the applicant’s property, including property of the applicant held by third parties. The High Court, which appointed the Receiver under section 80 (2) of the 1988 Act on application by the CPS and after the applicant had been given a further opportunity to pay the confiscation order, ordered that the Receiver’s powers were not to be exercised until the interests of the restrained properties had been determined.

On 2 September 1996, following an application on behalf of the Ministry of Defence in separate civil proceedings, the applicant was declared bankrupt. Ms S.D. was appointed as the applicant’s Trustee in Bankruptcy. This appointment was independent of her appointment as Receiver.

Following an ex parte application by the Receiver and Trustee in Bankruptcy, Ms S.D., the District Judge at Reading County Court ordered, on 27 September 1996, that:

“for a period of three months from the 27th day of September 1996 all postal packets (as defined by section 83 of the Post Office Act 1953) directed or addressed to the Bankrupt ... shall be re-directed, sent or delivered by the Post Office to [the Trustee in Bankruptcy’s address].”

The Order was made under section 371 of the Insolvency Act 1986 in favour of Ms S.D. in her capacity as the applicant’s Trustee in Bankruptcy. The application was based on the grounds that the Trustee in Bankruptcy was of the opinion that communications concerning remittances and useful information in respect of the applicant’s assets and liabilities which would better enable her to perform her duties may be forwarded to the applicant’s address and may be lost to the applicant’s estate if the Order were not made. The grounds invoked were supported by an affidavit sworn on 27 September 1996, which affirmed that it was necessary for postal packets to be intercepted immediately and without notice to the applicant to enable the Trustee in Bankruptcy properly to identify the applicant’s assets and sources of income.

An exception was made in the Order of 27 September 1996 for letters on which there was a specific direction, signed by the Trustee in Bankruptcy, that the letter was to be delivered as addressed, if possible.

Between 27 September 1996 and 10 January 1997, a total of 71 letters addressed to the applicant were re-directed to the Receiver and Trustee. These letters included, inter alia , a letter from the Chief Inspector of the Ministry of Defence Police, two letters from the Legal Aid Board concerning civil proceedings to which the applicant was a party, a letter from the Police Complaints Authority, two letters from his legal advisers, the Legal Department of the National Council for Civil Liberties (later referred to as “Liberty”) relating to the proceedings before the European Commission of Human Rights, and affidavits and drafts made or prepared for use in the High Court in relation to the bankruptcy and receivership proceedings.

Each of the letters mentioned above was copied to file before being forwarded promptly to the applicant.

In his letter of 28 November 1996 to the Receiver and Trustee in Bankruptcy the applicant expressed particular concern that apparently privileged material was being intercepted. On 2 December 1996 the Receiver and Trustee replied that no mail from the Police, Legal Aid, the National Council for Civil Liberties and the European Court of Human Rights would be opened in the future, as long as they were clearly stamped on the envelope.

Although the re-direction Order expired on 27 December 1996 it was only as from 18 January 1997 that the applicant began to receive his mail directly again. During that period there were two mail deliveries to the Trustee in Bankruptcy. The deliveries contained ten items of mail none of which fell within the categories described above.

On 25 February 1997 the applicant issued a summons for a stay of the receivership proceedings pending the determination of his application to the Commission. The hearing was listed for 16 June 1997 but was adjourned to 19 February 1998. On that date the High Court dismissed the application and confirmed that the receivership proceedings should continue. The applicant has not informed the Court of any subsequent developments in the receivership proceedings.

B. Relevant domestic law

Interception of correspondence

Section 371 of the Insolvency Act 1986 empowers the court as follows:

“1. Where a bankruptcy order has been made, the court may from time to time, on the application of the official receiver or the trustee of the bankrupt’s estate, order the Post Office to re-direct and send or deliver to the official receiver or trustee or otherwise any postal packet (within the meaning of the Post Office Act 1953) which would otherwise be sent or delivered by them to the bankrupt at such place or places as may be specified in the order.

2. An order under this section has effect for such period, not exceeding three months, as may be specified in the order.”

Trustees in bankruptcy have other statutory powers, which are more stringent than the power to apply for a re-direction order but which may nonetheless need to be used, in appropriate cases, if Trustees are properly to investigate the bankrupt’s affairs for the ultimate benefit of his creditors. In particular, under section 365 of the Insolvency Act 1986 a Trustee may obtain a warrant authorising him to seize property, books and/or records falling into the debtor’s estate. Furthermore, section 366 of the Act allows the court (on application by a Trustee) to summon a variety of persons before it to give an affidavit and/or produce documents.

A bankrupt owes a statutory duty, pursuant to section 333 of the Insolvency Act 1986, to give to the Trustee such information as to his affairs, attend meetings with the Trustee and do such other things as the Trustee may reasonably require for the carrying out of his relevant functions.

COMPLAINTS

The applicant complains that the confiscation order against him constitutes a retroactive imposition of a criminal penalty contrary to Article 7 § 1 of the Convention. The applicant refers in this respect to the Court’s judgment of 9 February 1995 in the case of Welch v. the United Kingdom (Series A no. 307-A).

The applicant further complains that the interception of his correspondence over the period 27 September 1996 to 18 January 1997 by the Post Office on behalf of the Receiver and Trustee in Bankruptcy violated his rights under Articles 6, 8 and 34 of the Convention in that privileged and confidential communications were re-directed to the Receiver and Trustee in Bankruptcy although these communications related both to proceedings pending before the Commission and on-going litigation in which the Receiver and Trustee in Bankruptcy herself was involved. Furthermore, after the expiry of the re-direction Order his mail continued to be re-directed to the Receiver and Trustee until 18 January 1997.

PROCEDURE

The application was introduced on 14 November 1995 and registered on 1 October 1996.

On 4 March 1998 the European Commission of Human Rights decided to communicate the application to the respondent Government.

The Government’s written observations were submitted on 30 July 1998, after an extension of the time-limit fixed for that purpose. The applicant replied on 22 December 1998, also after an extension of the time-limit.

The Government submitted further observations on 30 March 1999 after an extension of the time-limit and the applicant submitted observations in reply on 26 May 1999.

On 9 November 1998 the Commission granted the applicant legal aid.

On 1 November 1998, by operation of Article 5 § 2 of Protocol No. 11 to the Convention, the case fell to be examined by the Court in accordance with the provisions of that Protocol.

THE LAW

1 . The applicant maintains that the imposition of the confiscation Order infringed Article 7 § 1 of the Convention, which provides:

“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 argue that the applicant’s complaint should be dismissed on account of his failure to comply with the six-month rule laid down in Article 34 § 1 of the Convention. In their submission the applicant has not established that he sent a letter to the Commission within six months of the date of the judgment of the Court of Appeal in his case, namely 6 February 1995.

In this connection, the Government contest the genuineness of two letters which the applicant claims were sent to the Commission on 17 May and 7 July 1995 respectively. They assert that the original of neither of these letters, sent by C&J Legal Services in the capacity of the applicant’s representative at the time, is contained in the Commission’s case file. The Secretariat of the Commission confirmed this fact in a letter dated 13 May 1998. The Government stress that the disputed letters were never acknowledged by the Commission. Furthermore, the purported copies of these letters produced on behalf of the applicant, over a year after the expiry of the six-month time-limit, bear no marks which could identify them as having been sent on 17 May or 7 July 1995, and no proof of despatch has been furnished by C&J Legal Services. As further substantiation of their suspicion about the genuineness of the impugned letters, the Government draw attention to the fact that the application, allegedly sent on 10 October 1995, made no mention of any earlier correspondence with the Commission.

In a further submission the Government contend that the integrity of the individual who headed C&J Legal Services and whose name appears on the letterhead of the disputed letters, C.W., is to be questioned. They state that C.W. has been convicted of serious offences of dishonesty, in particular perjury and perverting the course of justice, and has also sought to mislead the Government about the status of his organisation. In the Government’s view, C.W. deceived the Commission.

The applicant, now represented by Liberty, maintains that the challenge to the admissibility of the application under this head only concerns the complaint under Article 7 of the Convention seeing that the six-month time-limit for the complaints under Articles 6 and 8 only began to run as from 24 January 1997, the date on which the last of his intercepted correspondence was forwarded to him. The applicant points out in support of this submission that Liberty filed a detailed forty-two page application on 2 May 1997, which was within the six months’ time-frame.

The Government do not dispute this argument.

The applicant states that the Secretariat of the Commission had accepted Liberty’s suggestion that the date of introduction of the application should be amended to refer to 7 July 1995 and not taken to be 14 November 1995 as initially determined by the Secretariat. This proposal has been motivated by their understanding from their contacts with the Secretariat that the case file held by the Commission contained both letters and that it was the letter of 7 July 1995, rather than the earlier letter, which set out the substance of the applicant’s complaints under Article 7. It was therefore with surprise that Liberty subsequently learned, following the correspondence between the Commission and the Government at the stage of communication of the application, that the originals of these letters were missing from the case file.

On behalf of the applicant, Liberty state that one of its representatives interviewed C.W. and obtained a sworn affidavit that he had personally typed, faxed and posted the letter dated 17 May 1995 to the Commission and that he had personally typed and faxed the letter dated 7 July 1995. The Secretariat of the Commission acknowledged receipt of the first letter in a letter dated 14 June 1995, which Liberty considers to be genuine. The Commission’s acknowledgement was received by C.W. in September or October 1995 in an envelope postmarked 26 September 1995. These circumstances suggest that there had been an administrative error in the handling of the case papers and that the letter of 17 May 1995 had gone missing as a result. Although C.W. was unable to produce any acknowledgement by the Commission of the letter of 7 July 1995, it was noteworthy that that letter claimed to contain counsel’s opinion and it had been established that counsel signed his opinion on 3 July 1995.

The applicant further states that while he was in prison he received a copy of a letter dated 25 September 1995, addressed to C&J Legal Services, purporting to emanate from the Commission and purporting to acknowledge receipt of an application “for a full hearing before the Council of Europe”. However, Liberty concede that this letter, unlike the Commission’s letter of 14 June 1995, appears not to be a genuine document.

The Government maintain in reply that the authenticity of the Commission’s letter of 14 June 1995 purportedly acknowledging receipt of the C.W.’s letter of 17 May 1995 must also be called into question. They highlight in this connection that the applicant claims that the letter was contained in an envelope postmarked 26 September 1995. In the Government’s assertion the only plausible inference to be drawn from the discrepancy between the date of the letter and the date stamped on the envelope is that the application form was despatched in that envelope and not a letter supposedly dated 14 June 1995. In any event, the letter of 14 June 1995, leaving aside its questionable authenticity, cannot assist the applicant since it only purported to refer to the alleged letter of 17 May 1995 which did not set out the substance of his complaints. The applicant’s case under the six month rule rested entirely on whether or not the letter of 7 July 1995 was sent to the Secretariat as alleged.

The applicant asserts in reply that to the extent that the Government maintain that C.W. deceived the Commission, then it must also be concluded that he was also deceived by C.W. The applicant maintains that he was at no stage at fault and had relied on C.W. to initiate the Convention proceedings on his behalf.

The Court recalls that according to Article 35 § 1 of the Convention it may only deal with an individual application after all domestic remedies have been exhausted, according to the generally recognised rules of international law, and within a period of six months from the date on which the final decision was taken.

As to the applicant’s complaint under Article 7 of the Convention, the Court notes that it is not disputed that the final decision is constituted by the Court of Appeal’s decision of 6 February 1995 rejecting the appeal’s appeal. It must be determined whether the applicant’s complaint under this head was duly lodged, at least in substance, within six months of that date. The Court further notes in this connection that Rule 47 § 4 of its Rules of Court stipulates that:

“The date of introduction of the application shall as a general rule be considered to be the date of the first communication from the applicant setting out, even summarily, the object of the application. The Court may for good cause nevertheless decide that a different date shall be considered to be the date of introduction.”

The Court observes in this connection that it is the applicant’s case that a letter was sent by his former legal representative to the Commission on 17 May 1995. However the Court notes from its examination of the case file that no such letter was registered by the Commission and there is no trace of a letter of acknowledgement of receipt having been sent. It stresses that the letter allegedly sent by the Commission on 14 June 1995 and received sometime in September 1995 by the representative at the time cannot be considered a bona fide letter of acknowledgement. The Court notes that that letter bears a number which, according to the Commission’s numbering system for provisional files, could not have been allocated in June 1995. The formatting of the letter is also inconsistent with the Commission’s standard practice at the time and there is no trace of a copy of that letter in the file. The applicant’s representative in the proceedings before the Court admits that the letter allegedly received by him from the Commission, dated 25 September 1995, is an obvious forgery. In the Court’s opinion, there are compelling indications that the letter purportedly sent on 14 June 1995 is not a genuine communication from the Commission either.

It is common ground between the parties that the key letter for the purpose of ascertaining whether the applicant has brought his complaint within the six month rule is the letter allegedly sent by his representative to the Commission on 7 July 1995. The Court confirms that the original of that letter has not been filed by the Commission and that there is no trace of a letter of acknowledgement of receipt having been sent. Although the applicant’s representative has provided elements in support of his argument that such a letter was sent, the Court does not consider these to be in any way conclusive. Furthermore, it is highly improbable that two letters in a row could be mislaid by the Commission. Having regard to its conclusion on the letter allegedly sent on 17 May 1995, the evidence weighs heavily in favour of a finding that an attempt was made to mislead the Court into believing that a letter dated 7 July 1995 containing the substance of the complaint had been despatched to the Commission. Indeed, the case file clearly indicates that the first communication from the applicant was logged by the Commission on 14 November 1995. Significantly that communication, transmitted by fax, only enclosed a copy of the letter dated 17 May 1995. It contained no reference to a letter having been sent on 7 July 1995. In addition, the claim made by the applicant’s representative at the time that he posted a completed application form to the Commission on 10 October 1995 must also be regarded with suspicion since there is no trace of the hard copy in the case file. A completed application form, containing no reference to the letter of 7 July 1995, was only transmitted by fax to the Commission on 14 November 1995.

In these circumstances the Court considers that the date of introduction of the complaint must be taken to be 14 November 1995, which is more than six months after the Court of Appeal’s decision of 6 February 1995. The complaint is therefore inadmissible under Article 35 § 1 of the Court. Indeed, it could equally be rejected as an abuse of the right of application within the meaning of Article 35 § 3 having regard to the subterfuge employed by the applicant’s original representative. The Court would add that this conclusion is not to be seen as impugning the integrity of the applicant’s current representative who was in no way involved at that stage of the proceedings.

The Court concludes that the applicant’s complaint under Article 7 § 1 of the Convention must be rejected pursuant to Article 35 §§ 1 and 4.

2 . The applicant submits that the interception of his correspondence over the period 27 September 1996 to 18 January 1997 by the Post Office on behalf of the Trustee gives rise to a breach of Article 8 of the Convention, which provides as relevant:

“1. Everyone has the right to respect for ... his correspondence.

2. There shall be no interference by a public authority with the exercise of this right except such as is in accordance with the law and is necessary in a democratic society in the interests of national security, public safety or the economic well-being of the country, for the prevention of disorder or crime, for the protection of health or morals, or for the protection of the rights and freedoms of others.”

The applicant also avers that the failure of the relevant legislation and the Order of 26 September 1996 to protect his correspondence with the Commission, and with the lawyers advising him on his application, breached his right of individual petition (Article 34 of the Convention) especially since his correspondence with his legal advisers was clearly marked as such.

The applicant does not dispute that the measure taken by the authorities is capable of pursuing a legitimate aim, namely to prevent the dishonest concealment of assets and hence the protection of the rights of the applicant’s creditors and of the taxpayer. However, in his submission the interference was (a) neither in accordance with the law nor (b) necessary in a democratic society.

As to the first limb, the applicant considers that the Insolvency Act 1986 does not define with sufficient clarity the scope and manner of the exercise of discretion to re-direct and intercept mail. The applicant observes in this connection that neither the Act nor the re-direction Order of 26 September 1996 make any provision for dealing with legally privileged material and that his correspondence continued to be re-directed after the date of expiry of the Order. He further notes that Ms S.D. was both the Trustee in Bankruptcy and the Receiver, and in the former capacity had access to, read, copied and retained legally privileged communications concerning his challenge to the enforcement of the confiscation Order.

As to the second limb, the “necessity” test, the applicant highlights what he considers to be the unacceptable scope of the powers granted to the Trustee in Bankruptcy. These powers enabled her to have access to correspondence with his legal advisers. In the applicant’s opinion, the re-direction Order could have excluded the re-direction of clearly marked legally privileged materials without impairing the aim of the Order. Moreover, the implementation of the Order was not accompanied by adequate and effective safeguards which would have avoided the re-direction of such materials to the Trustee in Bankruptcy which concerned on-going litigation to which the latter was herself a party, albeit in a different capacity.

The Government acknowledge that the following letters were among the correspondence re-directed to the Receiver and Trustee in Bankruptcy before the expiry of Order of 27 September 1996: two letters from the Legal Aid Board, two letters from the Legal Department of Liberty, a letter from the Police Complaints Authority, and a letter from the Chief Inspector of the Ministry of Defence Police. Each of these letters was copied for file before being forwarded promptly to the applicant. There were two mail deliveries to the Trustee in Bankruptcy after 27 December 1996, when the Order had expired. One delivery was received on 30 December 1996, the other on 10 January 1997. Neither fell into the categories of letters previously mentioned and the fact that they were re-directed after the expiry of the date laid down in the Order may be explained by a delay in implementing the procedures for discontinuing re-direction of mail.

The Government concede that the re-direction of the above-mentioned letters constituted an interference with the applicant’s right to respect for his correspondence. They maintain, however, that the interference was justified under the second paragraph of Article 8. They submit in this connection that the interference was proportionate in its effect on the applicant’s right under Article 8, was in accordance with the terms of an Order obtained under section 371 of the Insolvency Act 1986 and was intended to protect the rights of the applicant’s creditors. The Government stress in this latter respect that the re-direction Order had been sought in order to allow the Trustee in Bankruptcy to identify properly the assets and sources of income of the applicant with a view to the distribution of those assets to innocent creditors, a task which required that the Trustee in Bankruptcy have access to the applicant’s correspondence. The applicant had not co-operated in the receivership proceedings and there was concern that suspected unsecured foreign assets might be dissipated if measures were not taken to identify those assets. The Government state in this connection that there was no benefit for Ms S.D. as Receiver in attempting to gain further information under the re-direction Order since the confiscation Order of 8 August 1996 only empowered her to gain control of the title documents of the properties and assets detailed therein.

The Government further maintain that there is no reliable method of distinguishing letters which might assist the Trustee in Bankruptcy in the performance of her duties from other categories of correspondence such as letters from legal advisers. The envelope is of no assistance in this respect. Indeed, the Trustee in Bankruptcy was attentive to the applicant’s concern that his correspondence from the applicant’s legal advisers or the Convention institutions might be opened. She informed him that no such letters would be opened if the envelope clearly indicated the sender.

The applicant submits in reply that in addition to the letters referred to by the Government, the Trustee in Bankruptcy also copied and retained five letters passing between the applicant and S.K. who was acting on his behalf as an insolvency consultant and legal adviser in the domestic proceedings involving the Receiver. The applicant maintains that Ms S.D. must have been aware that she was the opponent of S.K. in the domestic litigation and for her to open, read, copy and retain S.K.’s correspondence with the applicant amounted to an obvious invasion of professional secrecy.

The applicant further contends that even if considerations of pragmatism may have some bearing on the reason why privileged correspondence could not be separated from other correspondence by the Post Office before mail was re-directed, there could be no pragmatic justification for the selective and systematic copying and retention of privileged correspondence. The applicant also stresses in this respect that the Government do not contradict his argument that the envelopes containing correspondence with Liberty were clearly identified on the outside. As to the Government’s explanation for the fact that certain items of correspondence were re-directed after the expiry of the Order, the applicant avers that the administrative difficulties relied on cannot serve to justify the fact that Ms S.D. opened, read and copied those items after they had been delivered to her and at a time when she must have been aware that the Order had expired.

The Court considers, in the light of the parties’ submissions, that the above complaint raises complex issues of law and fact under the Convention, the determination of which should depend on an examination of the merits. The Court concludes, therefore, that this part of the application is not manifestly ill-founded, within the meaning of Article 35 § 3 of the Convention. No other grounds for declaring it inadmissible have been established.

3 . The applicant maintains that the interception of correspondence between himself and his legal advisers concerning the proceedings relating to the enforcement of the confiscation Order violates Article 6 of the Convention, which provides as relevant:

“1. In the determination of his civil rights and obligations or of any criminal charge against him, everyone is entitled to a fair ... hearing ... . ...

3. Everyone charged with a criminal offence has the following minimum rights: ...

(c) to defend himself in person or through legal assistance of his own choosing...”

The Government disagree. In their submission, to the extent that there may be concerns about the interception of correspondence from the applicant’s legal advisers, those concerns fall to be considered from the standpoint of Article 8 of the Convention. They further maintain that, in any event, the re-direction of the applicant’s letters did not amount to a breach of Article 6.

The Court considers, in the light of the parties’ submissions, that the above complaint raises complex issues of law and fact under the Convention, the determination of which should depend on an examination of the merits. The Court concludes, therefore, that this aspect of the application is not manifestly ill-founded, within the meaning of Article 35 § 3 of the Convention. No other grounds for declaring it inadmissible have been established.

For these reasons, the Court, unanimously,

DECLARES ADMISSIBLE , without prejudging the merits, the applicant’s complaint that there has been an interference with his right to respect for his correspondence and that that interference, in so far as it concerned correspondence from his legal advisers, also interfered with his right to a fair procedure in respect of the receivership proceedings;

DECLARES INADMISSIBLE the remainder of the application.

S. Dollé J.-P. Costa

Registrar President