CASE OF SZANYI v. HUNGARYDISSENTING OPINION OF JUDGE WOJTYCZEK
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DISSENTING OPINION OF JUDGE WOJTYCZEK
1. I respectfully disagree with the approach adopted by the majority in the instant case. In my view, Article 10 is not applicable in the circumstances and the application should have been declared inadmissible. As Article 10 does not apply, there are no grounds for finding a violation of this provision.
2. Modern constitutional democracy is based on distrust toward State power holders. As Judge Saj ó eloquently explained in his masterpiece, “No matter how expensive the constitutional order or how alien and partly unsuccessful legal regulation of the political sphere is, one has to be suspicious of the state and those who exercise power” ( Limiting Government: an Introduction to Constitutionalism , Central European University Press, New York and Budapest 1999, p. 11, italics in the original). The main worry in a democratic State governed by the rule of law is how to place effective limitations on the actions of State officials. In this context, it is no surprise that the European constitutional tradition is based on certain clear distinctions: (i) between the individual and the State; and (ii) between private and official acts.
Human rights or fundamental rights protect the individual against the State. More specifically, they protect individuals while acting in their private capacity against illegitimate interference from State power. It is important to note in this respect that State power is exercised by individuals who are members of State organs and who act in an official capacity. Human rights do not protect State power holders, acting in their official capacity, against other State power holders (on this issue, see, in particular, W. Graf Vitzhum, Der funktionale Anwendungsbereich der Grundrechte in: Handbuch der Grundrechte in Deutschland und Europa , vol. II Grundrechte in Deutschland: Allgemeine Lehren , D. Merten, H.J. Papier (eds.), Heidelberg: C.F. Müller Verlag, 2006).
An act undertaken by an individual belongs either to the private or to the official sphere. Acts belonging to the private sphere may benefit from human-rights protection against acts belonging to the official sphere. Acts belonging to the official sphere cannot enjoy such protection. An individual may not invoke human-rights protection when he or she acts in his or her official capacity, especially when performing duties as a member of a State organ or a holder of State office. In the latter case, not only is the individual not protected by human-rights mechanisms, but he or she is bound by human rights in their vertical dimension (that is, in relations between the individual and the State). I have set out my views on these issues in detail in my dissenting opinion to the judgment in the case of Baka v. Hungary [GC], no. 20261/12 , ECHR 2016 ).
The general principle that human-rights legislation protects individuals acting in their private capacity and not as State officials is commonly accepted. At the same time, the delimitation between private and official acts is not always obvious (see, in particular, J. Schabe, Grundrechtschutz hoheitlicher Funktionsträger in: Staat-Souveränität-Verfassung. Festschrift für Helmut Quaritsch zum 70. Geburstag , D. Murswiek, U. Storost, H.A. Wolff (eds.), Berlin: Dunkcher Humblot, 2000). It may be a particularly difficult one in respect of acts performed by office holders who exceed the scope of their powers; in particular, the line between illegal official acts and illegal private actions by office holders may be open to legal dispute.
3. Specific legal problems arise in the case of parliamentarians ’ conduct. Parliament is by definition a venue where its members may speak freely and this is an indispensable element of a deliberative democracy. Speech in parliament is matter of the MP ’ s individual choice. It cannot be imputed to the State and a single MP cannot speak for the whole parliament. Adequate guarantees that the opposition ’ s voice can be heard in parliament are essential in a constitutional democracy. Issues placed on the parliamentary agenda may more easily attract the attention of the press and of citizens, and thus the ability to raise issues for discussion in parliament enables the opposition to trigger a broader public debate. It also forces the majority to engage in the debate and to take a stance on the issues under discussion. Furthermore, there is a fundamental difference between the situation of judges, whose freedom of speech is limited in many ways and, in particular, by the duty to speak in defence of judicial independence, and the situation of members of parliaments who enjoy the guarantees of a free mandate.
However, one cannot overlook the fact that speech in parliament is part of the parliamentary mandate. A free mandate is first and foremost a mandate granted by the people to its representative, in order to exercise State power in its name. Freedom of the parliamentary mandate is an essential element of the legal framework delimiting the scope of MPs ’ powers. The mandate granted to an MP by the people is very wide-ranging and encompasses broad discretion with regard to parliamentary speech. At the same time, speech in parliament is part of an MP ’ s official functions. In speaking, MPs take part in the exercise of State power within a legally regulated decision-making process. Free speech in parliament has its source not in the inalienable human dignity of the MP but in the (extensive but nonetheless not unlimited) delegation of power by the sovereign people. It does not serve the personal self-fulfillment of the MP, but rather the common good. In other words: free speech in parliament is granted by the citizens for the benefit of the citizens and not for the benefit of the parliamentarians. Speech by a citizen exercising his or her fundamental human right and speech by an elected representative in the decision-making process, undertaken in the name of the people and for the people, are two different things. The latter is not a human right but a matter of the proper organisation of State institutions and decision-making processes in a representative democracy.
Carl J. Friedrich elegantly presented the gist of the question in the following way:
“Speech is the essence of parliamentary activity, is the very blood of Parliament ’ s corporate body politics. But just as blood has to flow through well encased channels in order to fulfill its salutary function, so speech has to be circumscribed and regulated in Parliament. Not the Tohu-bohu of a multitude of voices, but the balanced and order procedure of speech and reply, of argument and of debate is ‘ speech ’ within Parliament. The privilege of the ‘ freedom of speech ’ is not an absolute privilege of an individual member, it is relative freedom compatible with the freedom of others. In the words of the Marquess of Hartington, when discussing closure in the House of Commons in 1882: ‘ ... the privilege of speech is a privilege which the House permits to be exercised for its own instruction, for its own information, in order to form its own opinion, and ... not a personal privilege to be used irrespective of the convenience and the efficiency of the House... ’ ” (C. J. Friedrich, Constitutional Governments and Politics. Nature and Development , New York and London: Harper & Brothers Publishers, 1937, p. 390).
Many decades have passed since these words were written, but their relevance remains unaffected.
More recently judge Saj ó explained the present functioning of parliaments in the following way:
“Contrary to all eighteenth-century myths about the popular mandate of individual representatives, in reality the members cannot make individual decisions. Only the faction as a body may decide. The reason why the members have rights at all is to enable to legislative machinery to continue working ... It is not the individual who is entitled to speak in parliament and to submit proposals but the majority and the opposition or the factions; parliament ’ s chivalry is directed at the opposition” ( Limiting Government... , op. cit ., pp. 131-132).
4. MPs may speak at different venues and in very different capacities: as citizens, as MPs faithfully performing their duties, sometimes as persons trying to obstruct the parliamentary procedure illegally or exceeding the scope of their official functions. It follows that the decision to classify an act of speech pronounced by an MP as private or official requires a thorough consideration of all the relevant circumstances.
I note that the Hungarian Constitutional Court in its judgment no. 3206/2013 AB of 4 November 2013 declared Article IX(1) of the Hungarian Fundamental Law applicable in principle to parliamentary freedom of speech (see the summary in paragraphs 32-38 of the reasoning in the Court ’ s judgment in the case of Karácsony and Others v. Hungary ([GC], no. 42461/13 , ECHR 2016 (extracts) ). The Court stressed, nonetheless, the specific features of this speech. Furthermore, the precise scope of parliamentary speech covered by Article IX(1) of the Hungarian Fundamental Law is not clear. In any event, the interpretative decision of the Constitutional Court which makes Article IX(1) of the Hungarian Fundamental Law applicable to parliamentary speech does not alter the fundamental difference between this speech and private speech from the perspective of the Convention.
The instant case is a perfect illustration of the fact that parliamentary speech may touch upon the rights of third persons, and that there is a strong need for efficient protection of third persons against abusive parliamentary speech which violates their rights. The fact that speech is uttered in an official capacity may considerably increase its ability to cause damage to third persons.
5. An interpellation is an instrument of parliamentary control over the Government. It enables an MP to obtain an official reply from a member of the Government and to trigger a vote in the chamber on the matter. If the Member does not accept the answer, the National Assembly decides on the acceptability of the reply. If the parliamentary chamber rejects the reply, it may call upon a parliamentary committee to elaborate a proposal on the measures to be taken.
The ability to lodge an interpellation is a power granted to MPs in order to ensure the proper balance between the legislative and executive branches. It is not an individual human right stemming from human dignity and serving personal self-fulfillment, but an element of State organization . Moreover, there are constitutional democracies where parliamentary interpellations on the Hungarian model do not exist.
There can be no doubt that presenting interpellations (in writing or orally) and commenting on the official reply during a session of the parliamentary chamber are acts performed in an official capacity. The interference complained of did not affect in any way whatsoever the applicant ’ s ability to speak in his capacity as a citizen. In my view, the acts of speech at stake in the instant case belong to the sphere of official speech and cannot enjoy the protection of the Convention. It follows that Article 10 is not applicable in the instant case.
6. The majority ’ s reasoning also raises objections of another type. The majority considers that an interpellation is a way of exercising a legally protected freedom and assesses the applicant ’ s interpellation with the conceptual apparatus of limitations on freedom. Such an approach is difficult to accept from the viewpoint of legal theory. An interpellation is not only a channel for expressing views, but is first and foremost a way of doing things with words (compare J.L. Austin, How To Do Things With Words , Oxford: Clarendon Press, 1963). The capacity to lodge an interpellation is not a freedom but a power in the Hohfeldian sense (see W.N. Hohfeld, “Some fundamental legal conceptions as applied in judicial reasoning” , The Yale Law Journal , Vol. 2 3, no. 1, November 1913, pp. 16 ‑ 59, and “Fundamental Legal Conceptions as Applied in Judicial Reasoning”, The Yale Law Journal , Vol. 26, no. 8, June, 1917, pp. 710 ‑ 770), or a competence as understood by A. Ross ( The Theory of Directives and Norms , London: Routledge and Kegan, 1968, pp. 130-133). The notion of power (competence) presupposes a precise determination of the power holder, the procedure for the exercise of the power, the possible content of the act to be performed, the scope of its addressees and the legal consequences. An act performed by the power holder can produce its intended effects only if it remains within the substantive and formal limits of the empowerment. Even assuming that the power of an MP to lodge interpellations is a human right protected under the Convention, it cannot be adequately assessed with the conceptual apparatus designed for the evaluation of restrictions on freedom.
7. The references to the above-cited Karácsony and Others v. Hungary judgment seek to convey the impression that the reasoning in the instant case follows that judgment. In fact, it extends the application of the standards established in Karácsony to a completely different type of factual circumstance.
In the case of Karácsony and Others v. Hungary the Court had to deal with unlawful actions undertaken by MPs in order to disrupt a sitting of parliament. Such actions, although undertaken within the precincts of parliament, are clearly outside the scope of a parliamentary mandate. The Court commented in that judgment that the impugned behaviours were not “a conventional manner for MPs to express their views on a given subject debated in the House” (§149). The question of whether or not those behaviours are protected under Article 10 is open to dispute; however, I recognize that there are serious reasons to consider them as private speech, uttered not in an official but in a private capacity and therefore protected by Article 10.
In the instant case, the actions under consideration were part of an interpellation procedure. The applicant expressed views either orally during the examination of his interpellation by the National Assembly (paragraph 6) or in a written document (paragraphs 9 and 11). There is no doubt that the applicant acted in his official capacity. The impugned behaviours belong to official speech uttered within the performance of duties of a member of parliament.
Unlawful actions aimed at obstructing and disturbing parliamentary debates on the one hand, and speech in interpellation procedures on the other are two completely different types of speech which should not be confused. The judgment in the instant case could not therefore rely on the judgment in the above-cited Karácsony and Others case, but was required to rule on new legal issues concerning the applicability of Article 10 to the official speech of parliamentarians. These issues have not to date been decided by the Court.
8. The fact that Article 10 is not applicable does not mean that other Convention rights cannot be at stake in the instant case. For this purpose, it is necessary to examine not only the nature of the acts and conduct with which the respondent State interferes, but also the nature of the interference complained of by the applicant. A Convention issue may arise where a State interferes with an activity not covered by any Convention rights if the interference, by its nature, affects an individual ’ s life, health, personal freedom or property.
I agree that, by imposing a fine, the Hungarian parliament did interfere with the applicant ’ s human rights as protected by the Convention and the Protocols thereto. A fine is clearly an interference with the right of peaceful enjoyment of possessions, protected under Article 1 of Protocol No. 1 to the Convention. This part of the application should have been communicated and examined under Article 1 of Protocol No. 1 and also under Article 13 in conjunction with Article 1 of Protocol No. 1.
At the same time, I see no interference with the applicant ’ s Convention rights in the refusal to accept two of his interpellations. Those measures did not affect the applicant in person and did not interfere with any of his activities undertaken in a private capacity. They did not restrict his personal freedom or infringe upon his property. In particular, the applicant was not prevented from speaking on the issues he wished to raise, either in his private or in his official capacity. The only effect of the interference was that those to whom his interpellation was addressed did not have to provide an official reply to the interpellation and that the interpellation could not be examined during a sitting of parliament. Thus, the measure touched upon the applicant ’ s capacity to perform his official duties as a member of the legislature. This probably amounted to an infringement of the domestic provisions providing objective-law guarantees for the parliamentary opposition, but not of the applicant ’ s subjective human rights. Therefore, t his part of the application remains completely beyond the material and personal scope of his Convention rights.
9. The judgment raises the most fundamental issues with regard to the understanding of human rights and their scope of application. It is based on strong implicit assumptions about the nature of human rights, which are accepted without the provision of any reasons for this acceptance. In my view, it is simply not possible to decide on the issue of the applicability of Article 10 to parliamentary speech without explaining the nature of the rights protected under the Convention. In particular, an explanation should have been given as to what a human right is, and to whom and against whom it offers protection. The public will judge whether the majority ’ s decision not to address those fundamental questions makes the reasoning more persuasive.
The reasoning in the instant case is based on the implicit assumption that behaviour by an individual may simultaneously be an exercise of State power and the exercise of a human right. I strongly oppose this view. Human behaviour belongs either to the private sphere or to the official sphere but it cannot belong to both. One cannot simultaneously claim the attributes of State power and human-rights protection. To hold otherwise, in defiance of the European constitutional tradition, would have required a thorough and extensive justification.
The majority ’ s approach results in the droit-de-l ’ hommisation of legal relations within the State apparatus. It artificially transforms issues of checks and balances within the organisation of the State into alleged human-rights issues. Under this approach, in deciding those issues the State cannot limit itself to seeking to optimise democratic decision-making processes, but must provide compelling reasons for not implementing certain constitutional solutions.
Yet expanding the personal scope of human rights affects the effectiveness of human-rights protection. It cuts off the branch on which the international human-rights protection system is seated. If every legal subject, including a holder of State power, is entitled to human rights, then we will end up with a situation in which no one enjoys effectively protected rights. Extending human-rights protection to State power holders when acting in their official capacity undermines the very idea of human rights.
10. The Karácsony and Others judgment is very problematic in its understanding of the principle of proportionality. It states that:
“...in the circumstances of the case the impugned interference with the applicants ’ right to freedom of expression was not proportionate to the legitimate aims pursued because it was not accompanied by adequate procedural safeguards” (§161).
Such an approach mixes two completely different issues: proportionality on one hand and due-process guarantees on the other. Proportionality is a matter of substantive law, whereas procedural safeguards belong by definition to the domain of procedural law. It is true that substantive and procedural law may meet in certain legal provisions (for instance in those pertaining to MP immunities), which may have both a substantive and procedural dimension. However, the two planes must be distinguished in so far as possible. Proportionality analysis is independent from due-process standards and serves to assess the substance of a measure. A restriction may be proportionate to the aim pursued without having being imposed with all the necessary procedural guarantees and, vice versa, a restriction imposed with the due process of law may violate the principle of proportionality.
The instant judgment seems to follow the same path, although the terms used are somewhat more ambiguous:
“For essentially the same reasons as the ones set out in paragraphs 148 to 162, in particular paragraphs 151, 154, 156 and 158 in Karácsony and Others – notably the absence of effective and adequate safeguards against the abuse of disciplinary powers, the lack of adequate reasoning in the decisions and the non-availability of a parliamentary procedure in which the applicant could have been heard – this interference cannot be considered ‘ necessary in a democratic society ’ within the meaning of Article 10 § 2 of the Convention” (paragraph 32).
The majority refrains from invoking the principle of proportionality but instead refers to the more general “necessity” clause.
I am not sure that the term “necessary” used in Article 10 § 2 and other similar limitative clauses encompasses procedural guarantees. Admittedly, when assessing the compatibility of an interference with Article 10 the Court has for some time considered whether there are sufficient procedural guarantees. However, the latter ’ s legal basis is not clear. Sometimes they are considered to be part of the proportionality test (see, for instance, Steel and Morris v. the United Kingdom , no. 68416/01, § 95, ECHR 2005 ‑ II ; Kyprianou v. Cyprus [GC], no. 73797/01, §§ 171 and 181, ECHR 2005 ‑ XIII ; Kudeshkina v. Russia, no. 29492/05 , § 83, 26 February 2009; Morice v. France [GC], no. 29369/10, § 155, ECHR 2015 ; and Cumhuriyet Vakfi and Others v. Turkey , no. 28255/07, § 59, 8 October 2013 ); sometimes they belong to the requirement of legality “prescribed by law” (see, for instance, the judgments in Sanoma Uitgevers B.V. v. the Netherlands (no. 38224/03, Chamber judgment of 31 March 2009 and Grand Chamber judgment of 14 September 2010, § 100 ); and sometimes they are applied without reference to any specific principle or words used in Article 10 (see, for instance, Lombardi Vallauri v. Italy , no. 39128/2005, § 46, 20 October 2009 ). Be that as it may, the Court has so far never convincingly shown that such guarantees stem from the wording of Article 10. Assuming that they do, they should be clearly separated from the proportionality test.
Given the nature of the non-verbal expression in question, I do not consider that the fine imposed upon the applicant was disproportionate. In this respect, I fully share the concerns expressed in the very persuasive separate opinion of Judge K Å« ris. Flagrant unparliamentary behaviour by parliamentarians is a no less serious threat to constitutional democracy, its proper functioning and legitimacy than undue restrictions on the tools of parliamentary control, which are initiated mainly by the opposition. The sanction in the instant case seems necessary in a democratic society, not only to protect the rights of other persons but also for the prevention of disorder in a constitutional democracy. Whether the procedure in which it was imposed was fair is a completely different matter.
11. The analysis by the majority omits one important aspect of the case. The question of procedural guarantees in disciplinary proceedings in parliament should be placed in the broader context of MPs ’ immunities and privileges as a whole. Hungarian Fundamental Law in its Article 4 § 2 (1) guarantees the immunities of members of parliament. Those guarantees are further substantiated in section 73 of the Parliament Act:
“(1) During and after the term of his or her mandate, the Member shall not be impeached at court or at other authority for the vote cast or the fact or opinion communicated by him or her in the course of exercising and in connection with his or her mandate.
(2) The immunity specified in paragraph (1) shall not apply to the liability of the Member under civil law and to the following criminal offences:
(a) agitation against a community, violation of national symbol, public denial of the crimes of the national socialist and communist regimes, misuse of top secret and secret data, misuse of confidential data, misuse of restricted data as laid down in Act IV of 1978 on the Criminal Code in force until 30 June 2013,
(b) incitement against a community, violation of national symbol, public denial of the crimes of the national socialist or communist regime, misuse of classified data as laid down in Act C of 2012 on the Criminal Code.”
(Official translation provided at the website of the Hungarian National Assembly, http://www.parlament.hu .)
Immunities are safeguards for the proper functioning of a democratic parliament. Their necessary “pendant” is restrictions on MPs ’ freedom of action with regard to the protection of order in parliament, and especially the disciplinary sanctions applied by that parliament. The peculiarities of internal parliamentary proceedings are closely connected to the fact the MPs are (at least partially) released from their criminal and civil liability in judicial proceedings. Any assessment of the adequacy of procedural safeguards within parliament should take into consideration the existence of procedural safeguards which are connected with parliamentary immunities and applicable outside parliament. From the perspective of substantive law, parliamentary immunities are a strong argument against the applicability of the general guarantees of freedom of speech to parliamentary speech. Immunities usually protect the exercise of State power from undue interference by other State organs rather than the exercise of human rights. In the case of MPs, they are granted because of the different nature of parliamentary speech, which is a means of participating in the exercise of State power, in a sphere where general freedom of expression does not apply. From the perspective of procedural law, they are a strong – albeit not a carte blanche – argument, in favour of accepting the peculiarities of internal parliamentary proceedings, which are fundamentally different from judicial proceedings. Legal provisions limit the possibility of enforcing the law against MPs in judicial proceedings because there are simultaneously other provisions which allow the initiation of proceedings based on different principles.
That being said, I fully agree with the view that financial sanctions should not be imposed on MPs in internal parliamentary proceedings without adequately guaranteeing to the interested party the right to be heard.
12. The majority criticises the respondent State on the ground that “ the Speaker ’ s proposal forming the basis for the sanction sustained by the applicant does not offer any transparent description of the impugned conduct, nor a consideration of the circumstances or detailed reasons for the decision ” (paragraph 31 of the judgment). This statement gives rise to several remarks.
Firstly, I note a certain contradiction in the majority ’ s approach. On the one hand, the description of the impugned conduct is considered not to be transparent, while, on the other, the majority has no doubt what the impugned conduct is and describes it, rightly, as grossly inappropriate and vulgar.
Secondly, I do not think that the description of the impugned conduct was insufficient in the circumstances of the case. The judgment refers to the description in the minutes of the sitting of 18 March 2013. Everyone understands the expression for which the applicant was fined and the reasons for which he was fined. Not only did the applicant not complain about the way his behaviour was described in the impugned National Assembly ’ s resolution, but his submissions show implicitly that this description was sufficiently clear in the circumstances of the case.
Thirdly, I note once again a complete inconsistency in the standards with regard to the provision of reasons for the authorities ’ decisions (see my concurring opinion in Schipani and Others v. Italy , no. 38369/09, 21 July 2015 ). A jury convicting a criminal in a criminal procedure is not obliged to give reasons for the verdict (see Saric v. Denmark (dec.), no 31913/96, 2 February 1999; Taxquet v. Belgium , [GC], no. 926/05, ECHR 2010; and Judge v. the United Kingdom (dec.) no. 35863/10 , 8 February 2011) – it suffices that the accused understands the reasons for his or her conviction. Yet the present judgment indicates that a parliament imposing a mere fine in disciplinary proceedings against an MP has to provide detailed reasons. What is the rationale behind placing a higher burden on a parliament in disciplinary proceedings than on a jury in criminal proceedings?
13. In many European States, the internal matters of parliament and especially disputes between parliamentarians and parliamentary organs are considered non-justiciable, as belonging to the constitutionally protected sphere of parliamentary autonomy. This tradition of non-justiciability must be taken seriously, based as it is on very profound reasons. The democratic rules of the game in a parliament are either sufficiently internalized by the political class and judicial review over internal parliamentary business is thus rendered superfluous, or they are not and judicial review is consequently ineffective.
Parliamentary matters which are considered non-justiciable at domestic level are even less justiciable at international level. Multiplying international judicial guarantees is not always the most efficient way of promoting and protecting constitutional democracy. International judicial review of internal decisions taken by national parliaments is a particularly strong interference with the political decision-making process at national level. In any event, it remains beyond the scope of the mandate of the European Court of Human Rights as defined in Article 19 of the Convention.
[1] . Translation by the Registry.
[2] . “ Dohány ” in the original Hungarian, literally meaning “ tobacco’ ’ but being as well an informal expression for cash .
[3] . The governing party.
[4] . Translation by the Registry.
[5] . The relevant part of Article 7 of the Fundamental Law provides: “(1) Members of the National Assembly may address questions to the Commissioner for Fundamental Rights, the President of the State Audit Office, the Prosecutor General, or the Governor of the National Bank of Hungary about any matter within their functions. (2) Members of the National Assembly may address interpellations or questions to the Government or any of its members about any matter within their functions.”
[6] . Section 90(4) of the Rules of Parliament reads as follows: “The Speaker of Parliament shall refuse an interpellation introduced not in accordance with paragraphs (1) to (3). He shall inform Parliament thereof at its next sitting day.”
[7] See at
http://www.parlament.hu/orszaggyulesi-naplo-elozo-ciklusbeli-adatai?p_auth=yK3CFyAb&p_p_id=pairproxy_WAR_pairproxyportlet_INSTANCE_9xd2Wc9jP4z8&p_p_lifecycle=1&p_p_state=normal&p_p_mode=view&p_p_col_id=column-1&p_p_col_count=1&_pairproxy_WAR_pairproxyportlet_INSTANCE_9xd2Wc9jP4z8_pairAction=%2Finternet%2Fcplsql%2Fogy_naplo.naplo_fadat_aktus%3Fp_ckl%3D39%26p_uln%3D262%26p_felsz%3D37%26p_felszig%3D43%26p_aktus%3D11 .
[8] S ee at http://sgis.parlament.hu/archive/playseq.php?date1=20130318&time1=125815&offset1=004216.09&date2=20130318&time2=125815 &offset2=005216.09&type=real;
[9] S ee at http://24.hu/belfold/2013/11/18/megbuntettek-de-nem-fizet-szanyi-tibor .