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Tuesday, 25 July 2017

Is Al-shabaab planning to determine who wins in Kenya 2017?

 There is a surge in the frequency and intensity of terror attacks on Kenyan Soil. In an- 8 – week period  up to Mid-July, there were 15 terror incidents in Northern Kenya towns and Lamu county at the coast,  a majority of which involved blasts caused by IEDs.

The Mangled wreckage of an APC hit by Al-shabaab AIED
This is in sharp contrast to the situation between January and April this year, when only one or two incidents were reported per month in Wajir County, says Kenya’s stability and Risk Report for July this year.
The 15 incidents cost 55 lives a majority of them Security agents. Forty security agents including Policemen and Soldiers. The rest were civilians including four school children, nine adults beheaded and a relative of a Permanent Secretary who was killed as the terrorists abducted the PS. She was later rescued by the security forces.

Out of the 15 incidents, thirteen involved IED blasts targeting the security agents. The death toll from the incidents is also a sharp 690 percent rise from the situation in January to April when one death or none at all were recorded per incident. The current spate of attack averages 7 deaths per week.
All security officers were killed by IEDs. This is a worrying trend for targeting security agents destroys their vehicles thus slowing down police response time. It also instills fear on the officers, again slowing down their response time.

Aftermath of Mpeketoni attack in 2016

The 1500 Percent surge in terror activity coincided with the beginning of the Muslim holy month of Ramadhan during which terror activity increases. However, MEARisk warns that this could this be a precursor to bigger attacks.  The slaughter of nine villagers on July 8th, the first of its kind on Kenyan soil, but a common occurrence in Somalia, marked the acceleration of militant cruelty to a new high.

The report says that in April, the Kenya Defense Forces operating under AMISOM in Somalia killed 76 Al-shabaab operatives in Gedo region of Somalia. Before then, in March KDF had killed another 57 militants. Other attacks have also been reported in the Somali media where KDF has killed tens of militants.
So the killing of the 40 officers could easily be dismissed as revenge for Kenyan killings of Al- shabaab militants.
However, there is more to it than just revenge. It will be recalled than in 2013, Al- shabaab militants struck at Nairobi’s Westgate Mall killing 62 people. In 2015, Al-shabaab struck again, killing 148 students of the Garissa university college.
 In June 2014, Al- shabaab struck in Mpeketoni in Lamu County, killing 100 people.  In between 28 bus passengers, most of them teachers and nurses were killed in al-Shabaab attacks in Wajir. Quarry workers were also targeted.
 In February 2016, Al- shabaab attacked a Kenyan military base in El- Adde Somalia, killing an estimated 180 soldiers.
These events may appear unrelated, except that they had one common thread, they were designed to disillusion Kenyans at home to force them to demand the withdrawal of Kenyan forces from Somalia.  The government, for its part, has been firm that they will not be withdrawn.
If the earlier attacks had a political agenda, then they failed because Kenyan troops are still in Somalia thumping Al-shabaab at will.
The surge in terror activity so close to the elections in August 2017 could be a pointer to a political agenda. It could signal Al- shabaab’s desire to influence the forth coming elections in Kenya slated for August 8th, 2017. It could determine the winner!
 In 2014, Al-shabaab hit Mpeketoni just a day before the launch of the” Infamous US$2 billion” sovereign bond. Analysts then saw the attack as an attempt to sabotage the bond. That attempt failed as the bond was oversubscribed by 400 per cent.
 Can similar attacks be shrugged off this time around? This is an election year and Al-shabaab could be working to demoralize voters or to incite them to change the regime. Terrorists are known to influence an election through a surge in terror activities, says the MEARisk report.
Unlike 2013 and 2014, the security forces in Kenya have gained a lot of knowledge about the terror group. They have learnt to work jointly- sharing information and experiences.  This is one of the reasons Nairobi has become safe from Al- shabaab threat. However, this being an election year, Al- shabaab could try to be more cruel and daring.
 Perhaps attacking a crowded campaign rally in Kenya. Terror groups always do that. For instance, early in this decade, the Spanish rebel group, ETA, bombed a Railway station just a day before an election. The incumbent Prime Minister lost the election.

 If a crowded political rally is hit so close to the election, Voters would blame the government for failure to protect them, warns the report, and vote it out.

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Extract From "The Disintegrator" available ONLY through Looney-Tick Productions Shop: http://www.eafmcart.blogspot.it/p/shop.html
Preorders Will Be Sent Out October The 1st, 2015.
6 pro-cdr in 4-panel slipcases + 60 pages book.
Testing Vault "The Disintegrator" Is Available At A Special Price Of 40 Euros Until October 23, 2015. After That, The Price Will Be Of 60 Euros.
This Box Set, Limited To 50 Copies, Contains The First Attempt To Create, Thanks To A Series Of Intuitions, What It's Called "Cotard Ambience", Instead Of The Usual "Dark Ambient" or "Post Industrial" Labels.
Why? Read The Book, Discover The Various Audio Trailers By Yourself, And You'll Get The Puzzle Together.
Dedicated To Rozz Williams Last Premature Ejaculation's Double Album "Wound Of Exit", This Box Takes That Formula For Bringing It To Its Maximum Expression, In The Mostly Uncompromising Way Ever.
39 Songs For More Than 4 Hours Of New Music.
More Than Your Average Power Electronics Release.
Ps - if you don't hear nothing in the first minute and more circa, it is intentional. Holes Of Sound instead of "Walls Of Sound". Just relax and Enjoy The Video.

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Tuesday, July 23, 2013

SCRIPT No. 457, April 8, 2006

1830s, Here We Come

December of 1829 had been an unusually warm month; the following month remained so for a while. New York harbor remained free of ice. Visitor James Stuart was able to make quite a few visits to Manhattan from his boarding house in Hoboken, New Jersey, where he and his wife were staying.

Quite often his fellow passengers aboard the Stevens family steamboats were males; men did most of the marketing in the shops and stalls of Manhattan, returning later in the day with their produce and meats. Stuart had heard that even U. S. Chief Justice John Marshall, who occupied his residence on Staten Island when the Supreme Court was not in session, was often seen returning home with his dinner tucked under his arm, even the occasional turkey.

Most New Yorkers ate quite well. Stuart went to meet some friends for dinner once at a Manhattan boarding house. His shoes got dusty on the trip over; he stopped at a boot black’s house on Leonard Street for a polish, and found the man and his wife, “persons of colour”as he described them, “at dinner, consisting of one of the fattest roast geese I had ever seen, with potatoes, and apple-pie.”

In the several months they spent in Hoboken, many Sundays would find the Stuarts attending divine services in Manhattan. He mentions attending services at Episcopal, Presbyterian, Reformed Presbyterian, Baptist and Roman Catholic churches, as well as at several Methodist meetings. He found the various ministers to be equally impressive in their abilities. He was a little surprised when, turning up at the Oliver Street Baptist Church to hear the Reverend Spencer Wallace Cone, to find that he really had to hunt to find a vacant seat. “. . . the tide of Mr Cone's popularity was so great when I heard him, that the regular sitters were in some degree tenacious of their rights.”

It’s not too surprising that Cone was a popular preacher. The Princeton, New Jersey, native, had become an actor, much to the dismay of his devout mother, when he turned twenty. It may have been his presence during a fire that killed 72 people at the Richmond Theatre in the Virginia capital in 1811, including the state’s new governor, that made him decide to leave the stage. Afterwards, during a stint as a newspaper editor and writer, he was inspired by the biography of English divine John Newton to enter the Baptist church. Commanding a rifle company in the War of 1812, during which he witnessed the burning of Washington and the attack on Fort McHenry, he then moved to the nation’s capital. After preaching in the Washington and Philadelphia areas he moved to New York City in 1823 to take up the pastorate at the Baptist Church. Certainly Cone had a wealth of experiences to draw on, and by the time Stuart heard him, knew well how to work up a crowd.

The Stuarts must have done a bit of clothes shopping while they were in the area, probably in expectation of being on the road before long. He notes that most of the work in the fashion trade is done by women, apparently as opposed to the custom in Britain. The visiting couple may also have been refurbishing their outfits for the New Year’s celebrations to come at the end of the month. Well before Times Square was imagined.

© 2006 David Minor / Eagles Byte

Wednesday, July 17, 2013

English actor Joseph Jefferson makes his New York City debut in The Provoked Husband.    **    New York City's council solicits bids for a municipal water system, receives two. Nothing is done.

Mar 26
Matthew Clarkson, Thomas Eddy, John Murray, Jr., Isaac Sloatenburgh, and John Watts, are authorized by the state of New York to build a state prison on newly-acquired property on Greenwich Street in New York City, to be known as Newgate.

The New York City owner of a Barclay Street building destroyed by fire this month starts a public subscription drive for financial aid in recouping his losses.

A warehouse fire in lower Manhattan spreads northward from Wall Street, destroying close to 70 buildings between there and Maiden Lane, and costing $1,000,000. Water from the Tea Pump is used in fighting the blaze.    **    New York City's council once again solicits bids for a municipal water system, receives two (one from Westchester doctor Joseph Browne), both of which die in committee.

Dec 6
Leather dresser William Thomson, son-in-law of the Hardenbrook family, who took over the Collect property in lower Manhattan a few days ago, advertises in the New York Minerva promoting his tea water pump business on the property and countering some bad publicity.

Some black members of the John Street Church ask Bishop Francis Asbury to conduct separate services for them. He creates the African Chapel  (later the Zion A. M. E. Church) under the jurisdiction of the Methodist Episcopal Church.    **    The council rejects a state offer to purchase the site of the former Colles Water Works for a prison, turns the land into a dump for street waste.    **    Yellow fever kills several dozen people.    **    John Fitch tests his screw-propeller steamboat on New York City's Collect
 Pond. Passengers include Robert Fulton, Chancellor R. Livingston, passenger and inventor Nicholas Roosevelt, and young John Hutchings, who acts as steersman. John Stevens also experiments with steam on the pond.    **    The city attempts to get property owners around The Collect to agree to a canal to drain the pond. Nothing happens.    **    A steeple is added to St. Paul's Chapel.    **    The approximate date Benjamin Davis erects the Broadway House tavern on Broadway at Grand Street.     **    James Blackwell erects a clapboard farmhouse on Blackwell’s Island (formerly Varckens Eylandt, or Hog Island; later Welfare, then Roosevelt Island).    **    John Rogers buys four acres of the former Warren estate in lower Manhattan. The property will become the site of the first house to be built on Washington Square North (No. 20) in 1828 and 1829.

©  2013         David Minor         Eagles Byte


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• Post ID: 60002568 eastbay is an interactive computer service that enables access by multiple users and should not be treated as the publisher or speaker of any information provided by another information content provider. © 2017


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Obituary Archive for June, 2011

Rochelle Valentine

June 28th

Rochelle D. Valentine, 26, of North Webster passed away on June 27, 2011 in Valparaiso, IN.  She ..Read more..

Cindi Bajer

June 21st

       Cindi Bajer, 47, of South Bend, IN, passed away June 20,   2011, in her residence surrounded by ..Read more..

Monica May “Monk” Jernigan

June 6th

Monica May “Monk” Jernigan, 49, of Syracuse, IN passed away on June 5, 2011 at IU Health ..Read more..


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‘Daylight Donuts’ waitress disarms gun-toting felonious female

She says she probably wouldn’t do it again. But find out why others say that she gave the female bandit just what she deserved – and it wasn’t extra sprinkles on her donut …

Daylight Donuts, a locally-owned shop, is the scene of a bizarre robbery attempted that went bad – for the crook!

Story and photos by David F. Ashton
After the morning coffee-and-donut rush was over, just before noon on March 26, Jenny Abarca was cleaning up around the Daylight Donut shop, at 2613 SE 122nd Avenue, in the Midway Business District.

A middle-aged woman outside caught her eye, Abarca said – pacing back and forth outside the store.

When the woman finally came into the store, she made it clear she wasn’t there for coffee or a mid-day snack – she pointed a gun at Abarca, and demanded money from the cash register.

After the excitement ended, Jenny Abarca continued to work behind the counter at Daylight Donuts. Courtesy of KOIN Local 6

The lady bandit reportedly yelled, “’It doesn’t take that long to open a cash register,” as Abarca punched the buttons to open it.

The gun-pointing gal grabbed the money, Abarca related, then demanded more – before heading out the door, and turning to walking south, around the corner of the building.

“I don’t know why, but I decided to ‘take her down’,” Abarca told reporters – because the woman, said to be in her 30s or 40s, “didn’t appear to be all that menacing”.

When the robber’s gun-holding hand dropped this gas pipe, Abarca levered the gun out of her hand.

In the area in front of the deserted Albertson’s loading dock, the two women  scuffled. With the robber’s back against the brick wall, her hand holding the gun dropped below natural gas pipes that enter the building there.

“She grabbed my hair,” Abarca said, “and I grabbed the gun, and hit her in the head. She let go.”

The plucky employee also snatched back the stolen loot.

With no weapon and no cash, the bungling robber made a dash for freedom while Abarca went in the shop to call 9-1-1. “It’s probably not something I’d do again,” she said.

“The suspect was last seen possibly getting into a tan Dodge Neon that left westbound on Division Street,” reported Portland Police Bureau Public Information Officer Sgt. Peter Simpson. “Officers arrived and checked the neighborhood with a police K-9 unit, but did not locate the suspect.”

The bandit used what Simpson described as a “realistic-looking BB gun; and is a white female in her 30s or 40s, 5’4″ to 5’7″ in height, 120 pounds, dark blue jacket with a hood, black stocking cap, dark sunglasses, and wearing blue jeans.

Hours later, Daylight Donuts was back open for business.

“The suspect may have injuries to her face or head after being hit with the gun,” Simpson suggested.

Any tips you can give police could help take this robber off the streets before she gets a real gun and tries to victimize another shop’s employees. Call them in to Robbery Detectives at (503) 823-0400.

© 2012 David F. Ashton ~ East Portland News

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German Wine - An Experience Of Great Taste

Whatever you think to know about German wine ‒ put it aside and engage in a new experience of taste.

The wines, especially of the Southwest of Germany, are very rare and precious. They are combining a long history with a young and modern life ‒ so be part of it!

On the following pages you will find a selection of extraordinary rarities of wine. We hope, you will find your favorite wine for a lifetime!

If you have any questions, don't hesitate to contact us!

Please also take a look at our Facebook-Site!

Here you will find some pictures and funny things about wine at Pinterest!


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Saturday, February 9, 2013

Review: Sapphire Blue by Kerstin Gier

Sapphire Blue (The Ruby Red Trilogy, #2)

Sapphire Blue by Kerstin Gier
Book Two of the Edelstein Trilogie
Publisher: Henry Holt and Co.
Publication Date: October 30, 2012
Rating: 4 stars
Source: Public library

Summary (from Goodreads):

Gwen’s life has been a rollercoaster since she discovered she was the Ruby, the final member of the secret time-traveling Circle of Twelve. In between searching through history for the other time-travelers and asking for a bit of their blood (gross!), she’s been trying to figure out what all the mysteries and prophecies surrounding the Circle really mean.

At least Gwen has plenty of help. Her best friend Lesley follows every lead diligently on the Internet. James the ghost teaches Gwen how to fit in at an eighteenth century party. And Xemerius, the gargoyle demon who has been following Gwen since he caught her kissing Gideon in a church, offers advice on everything. Oh, yes. And of course there is Gideon, the Diamond. One minute he’s very warm indeed; the next he’s freezing cold. Gwen’s not sure what’s going on there, but she’s pretty much destined to find out.

What I Liked:

Oh, how I loved this sequel! I'm always fearful of sequels (second in the series), because many times, they are not as good as the first book. But this book was an excellent continuation of the series. I would say that the first book, Ruby Red, is overall better than this one, but this book is still really good.

Once again, Gwen shows us that she is a fantastic protagonist. She is neither weak or passive, and she does like give up without a fight. She is not necessarily feisty, in the way that we like to think of most YA heroines, but she has spunk. I love her insecurity, her humor, and her kindness towards others. This book continues Gwen's character development in a very good way.

I love the introduction of the new characters, especially Xemerius, a gargoyle demon, and Gideon's brother, Raphael. Xemerius is awesome! I distinctly remember this scene in which hre saves Gwen from humiliation in front of Chartlotte, when he describes to Gwen what a reticule is. And Raphael... I am excited to see where his interactions with Lesley will lead!

No love triangle. Unless you count Gideon and Charlotte. Which is not a love triangle, because Gideon does not reciprocate. It's more like Gideon and Gwen, with Charlotte trying to butt her way in. So not going to happen, Charlotte.

I love that Gwen's relationship with Gideon is fleshed out a little more. If you are thinking that they get it on, or some crazy action happens, get that out of your head right now. By the way, I am referring to "their relationship" as in, their interactions. In this book, they have no label, like "boyfriend" and "girlfriend". They skirt around each other a lot. Anyway. Gwen and Gideon both realize that they have strong feelings towards each other. Both handle this in different ways. Gideon is still hot and cold, sometimes leaving Gwen breathless, other times leaving her furious.

BUT. The ending is INSANE, in terms of their relationship. Gwen thinks one thing, and so do the readers. But, if readers keep going to the epilogue... they will see something that Gween does not know, but Gideon does (well, he is the one that discovers things, and reveals things, but not to Gwen).

The ending. I know, I am leaving out a lot of things that I would usually discus. But that ending. It. Is. CRAZY. Or insane, I think I said above. I love it so much, but then, as I said above, Gwen does not know things that Gideon and the readers do! So, it is really heartbreaking, but I have faith in the final book, Emerald Green. I cannot wait to see who has been messing with time, and what Paul and Lucy have been doing, and what Gwen and Gideon are going to do about the time-travel problems, and their own problems.

What I Did Not Like:

I feel like this book moved very slowly compared to the first book. No slow enough that made me finish the book slower (because I DEVOURED this book!), but slow enough that I noticed. The climax of the story was excellent, but I feel like the events leading up to it occurred too slowly. This is really my only complaint.

Would I Recommend It:

YES!!!!! I said this about the first book: I usually do not like time-travel books, but this series is so, so good. Try these books! BRITISH HOTTIES EVERYONE! (kind of)

4 stars. I need Emerald Green! I may have to order a foreign version, just so I will know months before! I have been learning Spanish in school for years...

Was this review helpful? Please let me know in the comments section!

  1. I'm so glad you enjoyed this one! There's always that little apprehension about reading sequels and I'm not very fond of slow books. Nonetheless, this does sound like a great series that I'll check out further. Great review! :)

    Sarika @ The Readdicts

    1. Trust me - this is a great series to read and follow! You should read Ruby Red - nand decide from there :D

  2. Just ordered this one. I totally missed it and can't believe it's been out since Oct and this is the first review I'd read on it. So glad that you enjoyed it. I have loved time travel books since I read The Man Who Folded Himself decades ago and this is an area of paranormal/fantasy that has had way too few books written.

    1. This comment is literally, like, PERFECTSO happy to hear that you're ordering it. I usuall dislike time travel books, because they usually aren't that well written, but this series certainly is! Thank you, Lisa!

  3. Hey Alyssa,
    I'm so glad you liked this successful series from my home country Germany. ;-) I've already read and reviewd the final book which is currently only out in German. You can check out my review here.
    Ruby Red has also already been made into a movie coming out this month over here. I'm not really sure whether I like the actor for Gideon though. Have a look at the trailer on YouTube and tell me what you think about them.

    Awesome review! Johanna

  4. I'm excited to read this one, but I'll have to go back and read Ruby Red first because I don't remember all of the details. Thanks for reminding me about it!

I love comments! I will always try and reply to your comments, as well as leave some comment love on your blog! :)

Also, this an award and tag free blog. While I am flattered that you would think of me, I really do not have the time to follow up. Thank you!


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Monday, October 27, 2008

Scotch Eggs @ The Wombat

Wow, what a crazy week already, and it's only going to get better. To kick off the first ever Free Lunch Week I'll post about brunch to get things rolling. Remember, the rules of Free Lunch Week are that you're free to eat whatever you want this week. Let me know what you get and if you'd recommend it to me. Don't worry about the impending economic doom or the slowing of your metabolism and you get older.

The Wombat is an Down-Under themed restaurant/bar serving Australian riffs on American cuisine in East Williamsburg. Looking at their menu I saw Scotch Eggs, which I have never had, so it seemed the obvious choice. For the uninitiated, scotch eggs are hard-boiled eggs encased in sausage and bread crumbs. They are deep fried and served with a sweet and savory mustard sauce. Also, they're awesome. Eggs, pork, and fried all equal a happy brunch customer.

What did you eat?

Falcon Steele said...

yo b! you need to be eatin up in them monkey brains! ya erd me! brains, son! brains!!!

karen said...

oh yum, this grilled farmhouse cheddar sandwich with oodles of sundried tomatoes, really is delicious. paired with some crazy technicolor cauliflower sauteed with garlic, and salvaged baby arugula, i'm in against-the-rules sandwich heaven. :)


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Cohort study
Alcohol consumption in early and late pregnancy is associated with poor child reading and writing ability at 8–9 years of age
  1. Beth Bailey
  1. Department of Family Medicine, East Tennessee State University, Johnson City, Tennessee, USA
  1. Correspondence to: Dr Beth Bailey, Department of Family Medicine, East Tennessee State University, P.O. Box 70621, Johnson City, TN 37614, USA; nordstro{at}

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Implications for practice and research

  • Women should be counselled that no amount of alcohol consumption during pregnancy can be considered safe, and heavy and binge drinking specifically can negatively impact child learning and school achievement.

  • Further research in other populations and addressing the limitations of this study is needed.

Nearly 1 in 10 children may be exposed prenatally to some level of alcohol. Forty years of research has demonstrated a link between prenatal alcohol exposure and a range of developmental problems in children, many of which impact academic achievement. Recent research has found that heavy drinking in early and late pregnancy, as well as binge pattern drinking throughout pregnancy, is associated with deficits in specific academic …

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Mix Fix: Dmitry K - Terrace Deep House

As promised, we're continuing this month's theme of good outdoor tunes, this week with Dmitiry K's Terrace Deep House mix from Mixcloud. Although this mix was recorded during the winter of 2009, don't be fooled - this Russian-born DJ of London knows how to keep it hot, even in the snow! So for your weekend patio party, keep the groove going with this hour or so of deep house tunes.

Genre: Downtempo Chill Out / Deep House / Lounge / Chill Out / Afterhours
Matthias Vogt, Doomwork & Aliya Moore, Deep House Souldiers, Duran Y Garcia, David Durango, Cavalier, Terry Lee Brown Jnr., Falko Brocksieper, Matthias Vogt, Ronin, Pete Gust, Kresy & Handrus, Limos

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Wednesday, 30 June 2010

Special Issue Greek Law Journal on ECHR

A special issue of the Greek Law Journal "Nomiko Vima" has just been published online with a range of articles celebrating last year's fifth decade of existence of the European Court of Human Rights. With over twenty contributions, mostly in English, some in French, from both Greek and European scholars and practitioners, this is a rich volume. It includes articles by a number of ECtHR judges, including Costa, Rozakis, Tulkens, and Spielmann. This is the full list of contributions:

1. D. Paxinos: Fifty years since the establishment of the ECtHR
2. The Editorial Board of Nomiko Vima: “Nomiko Vima” and its participation in the
celebration of 50 years of Strasbourg
3. J. P. Costa: La jurisprudence de la Cour Européenne des Droits de l' Homme et son
influence en France
4. C. L. Rozakis: The Particular Role of the Strasbourg Case-Law in the Development of Human Rights in Europe
5. A. Rantos: The Effect of the jurisprudence of the European Court of Human Rights on the jurisprudence of Greek Courts regarding the right to judicial protection
6. F. Tulkens: Migrants and their right to a family and private life under Article 8 of the European Convention on Human Rights
7. D. Spielmann: L’ extériorisation du vote judiciaire à la Cour Européenne des Droits de l'Homme
8. G. Nikolaou: Pronouncing on Human Rights
9. L. Kotsalis: DNA Bank, Safety and Human Rights
10. S. N. Ktistaki: The Prohibition of Discrimination in the granting of Social Benefits: Some thoughts arising from the recent jurisprudence of the European Court of Human Rights
11. A. Buyse: The Pilot Judgment Procedure at the European Court of Human Rights:
Possibilities and Challenges

12. L. Karelou: The influence of the jurisprudence of the European Court of Human Rights case law in Greece
13. M. Tsirli: Anachronistic Interpretations by Greek Courts and the European Court of Human Rights’ Corrective Role
14. P. G. Voyatzis: La privation de la propriété foncière, la Cour de Strasbourg et la réalité grecque: Variations de violations sur un même thème
15. Ch. D. Argyropoulos: European Convention on Human Rights: History and Adaptation.
The role of European Court of Human Rights
16. N. Frangakis: Systemic human rights violations in the jurisprudence of the European Court of Human Rights
17. V. Chirdaris: Criticizing Strasbourg, Lord Hoffmann, the Limits of Interpretation, the “Margin of Appreciation”, and the Problems Faced by the European Court of Human Rights
18. M. Tzifras: The European Court as a founding instrument for the implementation of
human rights
19. E. Salamoura: The right to be tried within a reasonable time and the restoration of the party’s “presumptive” prejudice
20. V. Chirdaris: The Greek part of the Strasbourg Court
21. P. G. Voyatzis: Dix arrêts importants dans la jurisprudence de la Cour Européenne des Droits de l’ Homme
22. S. D. Gryllis: La liberté de l’Europe
Many thanks to my friend Vassilis Chirdaris who did the editing of this special issue!

Tuesday, 29 June 2010

First Decision on Lack of a Significant Disadvantage

On the very day of the entry into force of Protocol 14, 1 June 2010, the Court immediately seized the opportunity to start using a new key admissibility criterion introduced by that Protocol, as a press release of the Court highlights this week. In the case of Adrian Mihai Ionescu v. Romania, the Court used the criterion that the applicant had not suffered a "significant disadvantage". The applicant's claim concerned a claim of 90 euros against a bus company with which he had travelled between Bucharest and Madrid, for not providing the promised services. In national court proceedings, his case was assessed his case and his complaints were rejected. The national Court did not rule on his request that the defendant company produce certain items of evidence. Higher courts dismissed his appeals.

The Court used the case to flesh out the three main elemenets of the admissibility criterion found in Article 35, parageraph 3: the Court can declare applications inadmissible if 1) "the applicant has not suffered a significant disadvantage", (2) unless respect for human rights as defined in the Convention and the Protocols thereto requires an examination of the application on the merits" and (3) "provided that no case may be rejected on this ground which has not been duly considered by a domestic tribunal."

As to the first and most crucial element the Court considered both the amount of the alleged loss itself (90 euros) and its relation to the applicants own (financial) circumstances. Neither of these indicated that the applicant was at a significant disadvantage. Thus the test under this first aspect is a double one: first a relatively external assessment of extent of the disadvantage in itself (which in case of financial loss is admittedly more easy to qualify) and second the relation of that loss to the particular situation of the allged victim. For a very poor person, a loss of 90 euros might of course be significant.

Secondly, the Court looked at whether the two "exceptions to the exception" led to a different conclusion. As to the respect for human rights, the Court concluded that the relevant legal provisions in Romania had been repealed and the case was in that sense of historical interest only. As to the question of whether the case had been duly considered by a domestic court, the Court answered this positively. Thus, it rejected the complaint.

In making its arguments under the three tests, the Court not only used the explanatory report to Protocol 14, but also its own earlier case law. In the case of the 'significant disadvantage' this noticeably included a range of dissenting opinions in earlier cases!

It may be noted that the Court assessed the case in detail and declared part of the complaint ill-founded - the admissibility of evidence issue was declared manifestly ill-founded, whereas the complaint about the proceedings in the higher courts were deemed not to be manifestly ill-founded or an abuse of the right to petition, but rather inadmissible under the new admissibility criterion. This seems to send out the signal that the Court will not too easily apply this criterion to do away with an entire application, but will use it with a caution that respects the various aspects of a complaint. This may assuage the concerns and fears of many, but on the other hand may diminish the efficiency gains of the new criterion. Let's hope the press department of the Court will keep highlighting new developments in these normally difficult to trace non-admissibility decisions.

The case itself is available only in French thus far, but a press release in English can be found here. For a short fact sheet on the reforms of Protocol 14, click here.

Friday, 25 June 2010

Article on ECHR and Abortion

Shannon Calt has just posted a comment on the upcoming ECHR decision in A, B, and C v. Ireland, a case on abortion. The article, entitled 'A., B. & C. v. Ireland: 'Europe's Roe v. Wade'?' was published in the Lewis & Clark Law Review Vol. 14, No. 3 (2010) p. 1189. This is the abstract:

In Ireland, abortion is illegal. In 2005, three Irish women who had previously traveled to England for abortions brought suit in the European Court of Human Rights asserting that restrictive and unclear Irish laws violate several provisions of the European Convention on Human Rights. The case was heard before the Grand Chamber of the Court on 12/09/2009 and a decision is forthcoming some time in 2010, perhaps 2011.

The European Court of Human Rights has never determined whether the Convention protects a right to life of the unborn or conversely any right to an abortion.The case at hand squarely presents an opportunity for the Court to take a position.

This comment focuses on Irish and European Court of Human Rights abortion law and the impending decision in A., B. & C. v. Ireland. I conclude that - based upon the Court's own jurisprudence - the European Court of Human Rights is very likely to declare that Ireland's nearly absolute abortion ban and the resultant effects of Irish law did and continue to violate rights the Court has already deemed protected by the European Convention on Human Rights. The Court will likely embrace one of two possible holdings. First, the Court could find that Ireland's abortion ban causes undesirable secondary effects such as inadequate post-abortion care, that these effects implicate rights under the Convention, and that Ireland has an unfulfilled positive obligation to mitigate these effects. Alternatively, I suggest that the Court may hold that Ireland's abortion ban itself violates the personal and family rights of applicants A., B. and C. and women like them. Commentators have referred to this case as “Europe's Roe v. Wade,” and I believe this to be an accurate if oversimplified statement.
For a statement of the facts in the case, click here and for the webcast of the hearing, which took place in 2009, click here.

Thursday, 24 June 2010

ECtHR Judgment: States not Obliged to Allow Homosexual Marriages

In a key judgment issued today, the European Court of Human Rights ruled on a complaint of a homosexual couple in Austria who were denied the right to marry. Although very recently (January 2010) Austria created the possibility to enter into a Registered Partnership for same-sex couples, marriage still is not possible. The applicants in this case, Schalk and Kopf, complained both under Article 12 (right to marry) and Article 14 (prohibition of discrimination) in conjunction with Article 8 (right to private and family life). The Court found no violation of their human rights, although it was very divided on the issue of discrimination (four votes against three in holding that Austria did not discriminate).

On the right to marry of Article 12 ECHR, the Court observed this was the first case in which it exmained whether people of the same sex had the right to marry. In earlier cases, the Court had looked at the position of transsexuals, in which it had concluded that (para. 53) "Article 12 enshrined the traditional concept of marriage as being between a man and a woman. The Court acknowledged that a number of Contracting States had extended marriage to same-sex partners, but went on to say that this reflected their own vision of the role of marriage in their societies and did not flow from an interpretation of the fundamental right as laid down by the Contracting States in the Convention in 1950." As to the litteral text of Article 12, the Court held that, looked at in isolation, the text "be interpreted so as not to exclude the marriage between two men or two women" (para. 55). But it then continued to add that "However, in contrast, all other substantive Articles of the Convention grant rights and freedoms to “everyone” or state that “no one” is to be subjected to certain types of prohibited treatment. The choice of wording in Article 12 must thus be regarded as deliberate. Moreover, regard must be had to the historical context in which the Convention was adopted. In the 1950s marriage was clearly understood in the traditional sense of being a union between partners of different sex."

The applicants asked the Court to interpret the text of Article 12 ECHR in the light of present-day conditions, an interpretation method which the Court has often used in the past to give a new or extended meaning to Convention provisions. This depends to a great extent on an evolving or developing consensus within Europe on a certain matter. In this case, however, the Court noted that there is no European consensus on same-sex marriage. To be precise, it stated that currently only six out of a total of 47 Convention states allow such marriages.

Interestingly, the Court also looked at the Charter of Fundamental Rights of the European Union (27 members) which includes in its Article 9 a right to marry without a reference to men or women, but with a reference to national law in accordance with which that right should be guaranteed. Thus, Article 9 of the Charter, leaves the decision to the states whether or not to recognise same-sex marriages (without oblgiing them to do so). On the basis of this, the European Court of Human Rights concluded on Article 12 that it "would no longer consider that the right to marry enshrined in Article 12 must in all circumstances be limited to marriage between two persons of the opposite sex. Consequently, it cannot be said that Article 12 is inapplicable to the applicants’ complaint. However, as matters stand, the question whether or not to allow same-sex marriage is left to regulation by the national law of the Contracting State." (para. 61). The door is thus left open a little bit, which basically affirms that those countries who do recognise and allow for same-sex marriages do so within the limits of human rights. This did not help the applicants of course. The Court went on to re-affirm that marriage has deep roots in societies and differs from one place to another. Considering this, it found it should not "rush to substitute its own judgment in the place of that of national authorities." To summarise, Article ECHR 12 does not oblige states to allow same-sex couples to marry.

The applicants may have foreseen this outcome and therefore also argued a violation under Articles 8 and 14 taken together. But that backdoor was also closed by the Court, since it held that the Convention's articles have to be interpreted in harmony with each other. The Court thus did not want to grant under these articles what it did not grant under Article 12. However, and here lies the importance of the present judgment, the Court did make a significant step by recognising that stable relationships of cohabiting same-sex couples fall within the notion of family life. This may seem self-evident to many, but for the Court it is a first. I cite the relevant paragraphs in full here:

93. The Court notes that since 2001, when the decision in Mata Estevez was given, a rapid evolution of social attitudes towards same-sex couples has taken place in many member States. Since then a considerable number of member States have afforded legal recognition to same-sex couples (see above, paragraphs 27-30). Certain provisions of EU law also reflect a growing tendency to include same-sex couples in the notion of “family” (see paragraph 26 above).
94. In view of this evolution the Court considers it artificial to maintain the view that, in contrast to a different-sex couple, a same-sex couple cannot enjoy “family life” for the purposes of Article 8. Consequently the relationship of the applicants, a cohabiting same-sex couple living in a stable de facto partnership, falls within the notion of “family life”, just as the relationship of a different-sex couple in the same situation would.

The Court then went on to look at the case from a non-discrimination angle in which it reiterated that differences made by the state based on sexual orientation required a serious justification. It also held, innovatively in its jurisprudence, that "same-sex couples are just as capable as different-sex couples of entering into stable committed relationships. Consequently, they are in a relevantly similar situation to a different-sex couple as regards their need for legal recognition and protection of their relationship." (para. 99).

Nevertheless, it went on to hold that since Austria had introduced a same-sex partnership it would not look at whether a total lack of legal ecognition of same-sex couples would violate the Convention, but only whether Austria had been obliged to offer any alternative way of legal recognition previous to the new partnership law. The Court held that Austria was not obliged to do so, with an explicit reference to the fact that there is "an emerging consensus towards legal recognition of same-sex couples" (para. 105) and that this was a rapidly developing tendency in the past ten years, but that currently no consensus existed yet (which it described as: there is no majority of states doing this yet). Consequently, states should enjoy a wide margin of appreciation. This margin also extended to the precise way in which alternatives (to marriage) of legal recognation fell within that margin. Thus the Court concluded that also on this count the Convention was not violated.
It must be noted, that on the issue of Articles 14 and 8, the Court came to its conclusion with a very small margin (four votes to three). The means that it might be wise for the applicants to ask the Court to have its Grand Chamber take a new look at the case on this very principled point. Indeed, as the three dissenters point out, there is a legal tension between saying that particular serious justifications are needed for such difference of treatment and then paradoxically not assessing whether such reasons where present, but rather going into the margin of appreciation question. Arguably, it is one or the other: the first approach suggests a rather small margin, the second implies that the justifications advanced by the state can be manyfold.

Thus this judgment seems to be a kind of Echternach procession: two steps forward, one step back (or even one step forward and two steps back, depending on ones perspective). It makes some important advances by recognising the at least factual and symbolic equality of same-sex and other couples, but it does not attach any far-reaching and clear legal consequences to that. Either a Grand Chamber judgment or a judgment in a different case which focuses on a situation in which any form of legal recognition in the country concerned was absent, should offer more clarity. The judgment seems to take a slightly too prudent approach for reasons of judcial politics (this outcome is the most acceptable to all states probably), but leaves us with a reasoning that is not entirely convincing nor an outcome which is very promising for same-sex couples.

It may be noticed that the government of the United Kingdom intervened on the side of Austria and that four NGOs (ICJ, FIDH, AIRE Centre and the European Region of the International Gay and Lesbian Association) intervened on the side of applicants.

New ECHR Academic Articles

Three new ECHR-related articles have recently been published. The first is authored by Nadezhda Purtova and has just been published in our own Netherlands Quarterly of Human Rights (Vol. 28, No. 2, 2010, pp. 179-198). It is entitled 'Private Law Solutions in European Data Protection: Relationship to Privacy, and Waiver of Data Protection Rights '. This is the abstract of the article:

This paper seeks to define how the legal categories of privacy and data protection correlate in the European legal system, and what the effects such a correlation has on the mode of data protection. Since the norms of the EC data protection law did not provide a conclusive answer, this paper turned to the ECHR for guidance. As a roadmap of analysis this paper picked the dichotomy between privacy and data protection based on the negative rights and positive obligations explained by De Hert and Gutwirth. The analysis of Art. 8 ECHR case-law led to the conclusion that the European Court of Human Rights does not limit the application of Art. 8 ECHR to private sphere only, and the provision on privacy protection has been applied as giving individuals positive rights (for instance, to refute false information about oneself) and imposing on the states affirmative obligations to create and ensure functioning of an effective system of data protection. The conclusion has been reached that European legal order treats data protection as a privacy interest.

Besides, it has been shown that legal recognition of such a close relationship is much more than just a matter of conviction on the philosophical meaning of privacy. Data protection benefits significantly from enjoying protection of a fundamental right status. Removal of data protection from the scope of privacy rights is not necessary and not desirable. First, development of the ECHR case-law expands privacy protection beyond negative right against state intervention to include affirmative obligations of a state to create a data protection system. Second, treating data protection as anything less than a fundamental right under Art. 8 ECHR will allow its waiver and thereby open the door for a dramatic change in approach to data protection.
The second is an article in the same issue of the Netherlands Quarterly, written by Andrew Drzemczewski, entitled 'The Parliamentary Assembly's Involvement in the Supervision of the Judgments of the Strasbourg Court'. This is the abstract:

Even though the Committee of Ministers of the Council of Europe has primary responsibility to supervise the execution of the judgments of the European Court of Human Rrights, by virtue of article 46(2) of the European Convention on Human Rights, the Parliamentary Assembly has increasingly contributed to the process of implementation of the Strasbourg Court's judgments. Composed of national parliamentarians, the Assembly can put pressure on states parties to the Convention to help ensure - through appropriate national parliamentary oversight procedures and mechanisms - rapid and complete implementation of Strasbourg Court judgments. This important Parliamentary dimension should be taken into account when the 2010 Interlaken declaration and action plan are implemented.
The third is an article in the European Journal of Crime, Criminal Law and Criminal Justice (2010, p. 225-236) by Tijs Kooijmans, entitled 'The Burden of Proof in Confiscation Cases: A Comparison between the Netherlands and the United Kingdom in the Light of the European Convention of Human Rights'. This is the abstract:

The Dutch Minister of Justice recently brought a legislative proposal before the Lower House in which a new broadening of the possibilities for deprivation of advantages was proposed. A comparison of Dutch law with the law of the United Kingdom is useful for a proper assessment of the value of the Dutch proposal. For that reason, the possibilities offered by the confiscation order in the United Kingdom are outlined in this paper. Next, it will be examined how, according to the case law of the ECtHR, the imposition of that confiscation order relates to the presumption of innocence as contained in Article 6 ECHR. Afterwards, the case law of the ECtHR will be represented by a Dutch case that shows some similarity to the imposition of the confiscation order in the United Kingdom. Lastly, several conclusions will follow.
Enjoy reading!

Wednesday, 23 June 2010

New German and Maltese Judges Elected

Yesterday the Parliamentary Assembly of the Council of Europe elected two new judges to the Court. With respect to Germany, the new judge will be Angelika Nussberger, currently law professor at the University of Cologne. The new Maltese judge will be Vincent Anthony De Gaetano, currently Chief Justice and President of the Constitutional Court, of the Court of Appeal and of the Court of Criminal Appeal. For the result of the vote relating to the German judge, click here. For the one relating to the Malteese judge click here. For the CVs, click here. The new Maltese judge will take up office within three months allowing the oldest judge on the Court, Giovanni Bonello, to finally retire. The new German judge will start working as of 1 January 2011. Both have been elected for a term of office of nine years.

Friday, 18 June 2010

Rendition Case to be Heard in Strasbourg

The case of the former terrorism suspect Khaled El-Masri is due to be considered in Strasbourg by the European Court of Human Rights, according to the Open Society Institute who is supporting his case. El-Masri was arrested by Macedonia in 2003, held incommunicado for over three weeks, and then handed over to the United States, under a practice known since a few years as extraordinary rendition, a very debated issue obviously. He was allegedly flown to Afghanistan, held and ill-treated there and eventually released in the countryside in Albania(!). After pursuing legal venues in vain within the American judicial system, his lawyers are now turning to the European Court, having lodged an application against Macedonia last year. For the press release of the Open Society Institute, click here. For more facts on the case and the application itself, click here.

See also the reporting on the Guardian Legal Network, of which this blog is also a partner, here.

Thanks to Darian Pavli of the Open Society Blog!

Thursday, 17 June 2010

Procedure for Electing Judges at the Court

The secretariat of the Committee on Legal Affairs and Human Rights of the Parliamentary Assembly has issued a document on the 'Procedure for Electing Judges to the European Court of Human Rights'. It is a handy summary of all the rules and developments on the issue of the last few years. The belated entry into force of Protocol 14 on the 1st of June extended the terms of office of the current judges and provides that newly elected judges will have a term of office of nine years. Still, several judges will retire from the Court after many years of acclaimed service. A timetable in the document indicates the foreseen elections for 2010 and 2011. These will include replacements for the highly valued President of the Court, Costa, in 2011 and of judges Jaeger of Germany and Rozakis of Greece later this year amongst others. A great loss of experience, for which one may hope highly qualified replacements will come. Last but not least, the end of the predicament of Maltese judge Giovanni Bonello (born in 1936) is in sight. He was due to retire in 2004 already but for lack of a replacement he is still going strong and continues to write his extremely well-phrased separate opinions, often imbued with a fine sense of irony - I can strongly recommend them to everyone!

Wednesday, 16 June 2010

Judgment on Non-Religious Education in Poland

Human rights in classrooms - it seems to be a topic of increasing popularity (or concern) in Strasbourg these days. Yesterday, the Court issued its judgment in the case of Grzelak v. Poland. The case concerned a Polish boy who refused to attend reilgious education in the various primary (and later secondary) schools he attended for reasons of personal conviction, with the full approval of his parents who were agnostics. Since, for a lack of other pupils in a similar situation no alternative courses such as ethics were offered, he had to spend such hours alone, apart from the other pupils. According to his parents that made him the subject of social ridicule and exclusion. In spite of various demands by the parents, no inter-school ethics were organised, since the number of interested pupils was too small. On his school reports, the place was the mark for religion/ethics was instead filled up by a straight line.

The first complaint related to the fact that the marking with a line, although seemingly neutral in effect revealed the convictions of the applicant against his will. For in practice, most schools did not offer ethics courses but only religious ones. A straight line under the heading 'religion/ethics' thus would reveal more than one might want. The Court considered this part of the complaint under Articles 9 (freedom of religion) and 14 (prohibition of discrimination) taken together. First the Court re-emphasized that Articel 9 also protected non-believers. In para. 87 it held:

It necessarily follows that there will be an interference with the negative aspect of this provision when the State brings about a situation in which individuals are obliged – directly or indirectly – to reveal that they are non-believers. This is all the more important when such obligation occurs in the context of the provision of an important public service such as education.
It continued by noting, in para. 93, on religious information:

The Court reiterates that religious beliefs do not constitute information that can be used to distinguish an individual citizen in his relations with the State. Not only are they a matter of individual conscience, they may also, like other information, change over a person's lifetime (see, mutatis mutandis, Sofianopoulos and Others v. Greece (dec.), nos. 1977/02, 1988/02 and 1997/02, ECHR 2002-X; and Sinan Işık v. Turkey, no. 21924/05, § 42, 2 February 2010). Although the above cases concerned identity cards, documents of arguably greater significance in a person's life than school reports for primary and secondary education, the Court nonetheless finds that similar considerations apply to the present case.
Especially in a country like Poland, with a great majority of the people adhering to one specific religion, the situation of the boy took on a "particular significance" (para. 95). In this case, in the Court's view, the very core of the boy's right not to manifest his convictions was infringed.

The second complaint related to the refusal to offer alternative courses in ethics to the boy. On that matter, the Court concluded under Article 2 of Protocol 1 (right to education) that Poland had remained within its margin of appreciation. After all, both religious and ethics education were optional and not compulsory, subject to the requirement that a minimum number of students is interested. The practice in Poland of a minimum seven pupils for such classes was in that sense not deemed unreasonable. No violation on that count therefore.

The Court was at pains to distinguish the case from its own decision in Saniewski v. Poland of 2001, in which it declared a very similar complaint on the straight line in school reports "manifestly ill-founded". The only dissenting judge in the Grzelak case, David Thór Björgvinsson, quite convincingly points out that the two cases are not that different. It seems rather that the Court, nine years later simply takes a different position. It would have been clearer if it would have openly argued so.

Monday, 14 June 2010

Article on Right to Individual Petition

Astrid Kjeldgaard-Pedersen of the University of Aarhus has just posted 'The Evolution of the Right of Individuals to Seise the European Court of Human Rights' (forthcoming in the Journal of the History of International Law) on SSRN. This is the abstract:

In at least two ways the year 2009 was a milestone for the European Court of Human Rights (ECtHR, the Court). On the bright side, the Court could celebrate its 50th anniversary and its continuous role as principal promoter of human rights in the 47 Member States of the Council of Europe (CoE, the Council). However, 2009 was also the year in which the number of pending cases before the Court passed the disturbing 100 000 benchmark.

Paradoxically, the main reason for both the Court’s success and its current crisis is the right of petition of individuals. The present article contains a detailed inquiry into the coming into existence of this central feature of the control machinery of the European Convention for the Protection of Human Rights and Fundamental Freedoms (ECHR, the Convention) that was labeled a breakthrough in the field of human rights as well as in general international law.

Parts I-IV of the article provide a chronological account of the drafting processes leading up to the adoption of the ECHR in 1950, and Protocol 9 in 1990. In analysis of reports and meeting minutes from a number of organs set up in the realm of the Council, the study concentrates on two main questions: Why did the original Convention end up excluding individuals from the proceedings of the ECtHR? And what changed in the time between 1950 and 1990 to facilitate the individual’s right to seise the Court independently?

As parts I-IV reveal, the development of the ECHR control machinery provides an interesting example of the interplay – or rather lack of same – between the practical decision-making among the parties to a convention and international legal theory. Part V reflects on the extent to which the theoretical discussion on the position of individuals in international law influenced the evolution of the right of individuals to seise the ECtHR.

Friday, 11 June 2010

Paper on Effective Application of ECHR and EC Law in Cyprus

Nikolas Kyriakou of the European University Institute in Florence has just posted on SSRN an article on the national implementation of European norms. The paper is entitled 'National Judges and Supranational Laws on the Effective Application of the EC Law and the ECHR: The Case of Cyprus'. It takes issue with the domestic effect of EU and ECHR law in Cyprus and analyses the changes that have occured in the national legal order for their reception.

Monday, 7 June 2010

Court Information Note on Pilot Judgments

It may have been online for some time already, but I only just saw it and would like to bring it to your attention: the Court's registry has drafted a short information note on the pilot judgment procedure. For more information on the pilot judgment procedure, see als the recent book 'An Analysis of 'Pilot Judgments' of the European Court of Human Rights and Their Impact at National Level' and my own article in the Greek Law Journal, entitled 'The Pilot Judgment Procedure at the European Court of Human Rights: Possibilities and Challenges'.

Friday, 4 June 2010

Religious Oath in Court Proceedings Judgment

In Greece, witnesses and suspects in criminal proceedings are required to indicate epxlicitly if they do not want to take an oath on the Bible. This way they are forced to reveal their religious( or non-religouis) convictions. Four different people complained about this in Strasbourg and yesterday won their case, in which they were represented by the Greek Helsinki Monitor. In Dimitras and others v. Greece the Court decided that such an obligation violated the freedom of religion under Article 9 ECHR. This is an excerpt from the Court's press release on the relevant part of the judgment:

The Court reiterated that freedom of thought, conscience and religion, which went hand in hand with pluralism, was one of the foundations of a “democratic society” and that in its religious dimension that freedom was an essential part of any believer’s identity, as well as being a precious asset for atheists, agnostics, sceptics and the unconcerned. It had already held that freedom to manifest one’s religious beliefs included an individual’s right not to reveal his faith or his religious beliefs and not to be obliged to act or refrain from acting in such a way that it was possible to conclude that he did or did not have such beliefs – and all the more so when aptitude to exercise certain functions was at stake.

The applicants had been considered as Orthodox Christians as a matter of course, and had been obliged, sometimes in hearings, to point out that they did not subscribe to that faith and, in some cases, to specify that they were atheists or Jews in order to have the standard wording of the minutes amended. In some court records they were expressly described as “atheists” or “of the Jewish faith”.

This interference with their freedom of religion had been based on Articles 218 and 220 of the Code of Criminal Procedure and pursued the legitimate aim of the proper administration of justice. Article 218 regulated the taking of the oath in court, on the Bible. It was thus presumed in the Code of Criminal Procedure that all witnesses were Orthodox and willing to take the oath, as reflected in the standard wording of the records of court proceedings. Indeed, it is only exceptions to the rule that Article 220 provides for, allowing those who were not Orthodox Christians to take the oath in conformity with another religion or to make a solemn declaration if they had no religion or their religion did not permit oath taking.

The wording of Article 220 actually required people to give details of their religious beliefs if they did not want the presumption contained in Article 218 to apply to them. Some of the applicants had had to convince the court officials concerned that they did not subscribe to any religion, failing which they would have had to take a religious oath. The incompatibility of the impugned legal provisions with Article 9 of the Convention was even more evident in Article 217 of the Code of Criminal Procedure, which stipulated that in any event all witnesses were required, amongst other information, to state their religion before testifying in criminal proceedings. The Court further noted that, unlike the Code of Criminal Procedure, the Code of Civil Procedure provided for witnesses, if they so wished and without any other formality, to be able to choose between taking a religious oath and making a solemn declaration.

The Court found that requiring the applicants to reveal their religious convictions in order to be allowed to make a solemn declaration had interfered with their freedom of religion, and that the interference was neither justified nor proportionate to the aim pursued. There had therefore been a violation of Article 9.
The problem was to be found firstly in the fact that the Code of Criminal Procedure itself started with the assumption that witnesses are Orthodox Christians and secondly that it preconditions exceptions to that rule on more information on the other religion (or lack thereof) that the witness adheres to, in order to decide on the kind of oath they are allowed to take. The practice is a clear example in which due to tradition a certain religion is given the main stage. It seems to me that this could be easily changed without prejudice to any religion into a more neutral provision, just as the one already existing in Greek civil law (and the ones existing in many other countries).

The judgment is available in French only, but the enitre English press release can be found here.

Thursday, 3 June 2010

Interventions in Crucifix Case

A few days ago, I reported this, but it seems that the information in the Maltese newspaper was not correct:

As various newspapers report this week, at least ten ECHR state parties will intervene as third parties in the extremely debated case of Lautsi v. Italy. After the Court concluded in its judgment in November 2009 that the obligatory crucifixes in Italian public schools violated the ECHR (see my earlier post on the case here), Italy asked for a referral of the case to the Grand Chamber. A panel of the Court indeed decided to grant this and the case will be heard in a public hearing in Strasbourg on 30 June. The countries involved, mostly with Catholic or Orthodox Christian majorities, are Armenia, Bulgaria, Cyprus, Greece, Lithuania, Malta, Monaco, San Marino, Romania and the Russian Federation. All states, and in addition 12 NGOs, intervene in support of Italy. According to the Maltese newspaper The Malta Independent, no country or NGO has asked for leave to intervene arguing in support of Lautsi's position. The very high number of intervening parties is unique in the Court's history, as far as I am aware. Whatever the outcome of the Grand chamber judgment, this will be keenly awaited and strongly scrutinised.
As the comments to this post by the Helsinki Monitor show (thanks for that!), the number of countries might indeed be lower and the interventions by NGOs are not only in support of the Italian position, but several are also in support of the position of the applicant. Let's await the hearing at the end of this month to see which arguments the Court will scrutinise in its questioning of the parties.

Wednesday, 2 June 2010

Paper on EU Accession to ECHR and Antitrust Law

Charlotte Leskinen of the Instituto de Empresa has just published a paper on SSRN on an economic law aspect of the EU's accession to the European Convention on Human Rights. Her working paper is entitled 'An Evaluation of the Rights of Defense During Antitrust Inspections In the Light of the Case Law of the ECTHR: Would the Accession of the European Union to the ECHR Bring About a Significant Change?'. For a related post on this blog, see here. This is the abstract of the paper:

The Lisbon Treaty provides that the European Union shall accede to the European Convention for the Protection of Human Rights and Fundamental Freedoms. This paper aims to establish whether the accession of the European Union to the ECHR would bring about a significant change regarding the protection of rights of defense that undertakings can invoke during inspections conducted in the course of investigations of alleged violations of the EU antitrust rules. The paper will examine the relevance of the case law of the European Court of Human Rights in this context by comparing the protection of the rights of defense granted under European Union law with the case law of the ECtHR. It will then draw some conclusions on the differences between the protection granted under European Union law and the ECHR and will outline the implications of the accession for the level of the protection of fundamental rights.

Tuesday, 1 June 2010

Protocol 14 Enters into Force

Today, a bit over six years after it was opened for ratifications, Protocol 14 finally entered into force. The Protocol reforms the supervisory machinery of the European Convention, rendering judicial decision-making more efficient. In addition, it introduces a new admissibility criterion: cases can be declared inadmissible if the applicant did not suffer a significant disadvantage. Finally, it opens up the possibility of EU accession to the ECHR.

The new, consolidated text of the European Convention on Human Rights and Fundamental Freedoms as amended by the Protocol can be found here. Reason for a small, but belated, celebration! Thorbjørn Jagland, the Council of Europe's Secretary General , and Jean-Paul Costa, President of the Court stated in a joint press release that "the entry into force of Protocol No. 14 represents a crucial step in improving the effectiveness of the Court and the protection of human rights in Europe. The Convention establishes the foundations of a common legal space across Europe. Protocol 14 will permit the Court to concentrate more on cases that raise important human rights issues, so it can play its role most effectively." That is only the first step of course as the follow-up - the Interlaken process - is just in its infancy.

Gäfgen Grand Chamber Judgment: Threatening with Torture and Fair Trial Rights

The Grand Chamber of the European Court of Human Rights just issued its keenly awaited judgment in the case of Gäfgen v. Germany today. The case centres on the fact that the applicant was threatened with torture when being questioned by the police. For the facts of the case and my analysis of the earlier Chamber judgment in 2008, see here. The Grand Chamber disagreed with the Chamber on a key point and decided that Mr Gäfgen, who had kidnapped and killed a young boy, could still be considered a victim, even though the German authorities had recognised violations of his human rights already at the national level. Specifically, it held that the punishments of the police officers involved had been relatively modest and did not function as sufficient deterrent for future violations. Thus, the Grand Chamber clearly once more wanted to send a strong signal on the absoluteness of the ban on torture (and even on the threat of torture). From this it followed that Article 3 ECHR had been violated. National authorities thus have to deal with such aberrations of their own personnel with utmost seriousness, even if the victim itself may not arouse a single grain of sympathy.

The Grand Chamber followed the ordinary chamber by holding that there had been no violation of Gäfgen's fair trial rights under Article 6 ECHR. Under both Articles (3 and 6) the Grand Chamber was divided (in both cases eleven votes to six). The various separate opinions are worhtwhile reading for some insights on the Article 3 discussions within the Court.

This is an excerpt from the press release:

Decision of the Court

Article 3

Treatment contrary to Article 3

It had been established by the German courts that a police officer, acting on the instructions of the Deputy Chief of Frankfurt Police, had threatened the applicant with being subjected to intolerable pain in order to make him disclose J.’s whereabouts. The Court considered that these immediate threats of deliberate and imminent ill-treatment had to have caused the applicant considerable fear and mental suffering. It observed that, as established by the domestic courts, the deputy police chief had ordered his subordinates on several occasions to use force against the applicant, his order could therefore not be regarded as a spontaneous act, but had been calculated in a deliberate manner.

The Court accepted that the police officers had been motivated by the attempt to save a child’s life. However, the prohibition on ill-treatment applied irrespective of the conduct of the victim or the motivation of the authorities; it allowed no exception, not even where the life of an individual was at risk. The Court considered that in the present case the immediate threats against the applicant for the purpose of extracting information from him were sufficiently serious to be qualified as inhuman treatment falling within the scope of Article 3. Having regard to its case-law and to the views taken by other international human rights monitoring bodies, it found, however, that the method of interrogation to which the applicant had been subjected had not reached the level of cruelty to attain the threshold of torture.

The applicant’s victim status

The Court was satisfied that the domestic courts, both in the criminal proceedings against the applicant and against the police officers, had acknowledged expressly and in an unequivocal manner that the applicant’s interrogation had violated Article 3.

It observed, however, that the police officers, having been found guilty of coercion and incitement to coercion, respectively, had been sentenced only to very modest and suspended fines. The domestic courts had taken into consideration a number of mitigating circumstances, in particular the fact that the officers had aimed to save J.’s life. While the Court accepted that the present case was not comparable to cases concerning arbitrary acts of brutality by State agents, it nevertheless considered that the punishment of the police officers did not have the necessary deterrent effect in order to prevent further Convention violations of this kind. Moreover, the fact that one of the police officers had subsequently been appointed chief of a police agency raised serious doubts as to whether the authorities’ reaction reflected adequately the seriousness involved in a breach of Article 3.

As regards compensation to remedy the Convention violation, the Court noted that the applicant’s request for legal aid to bring liability proceedings, following a remittal, had been pending for more than three years and that no decision had yet been taken on the merits of his compensation claim. The domestic courts’ failure to decide on the merits of the claim raised serious doubts as to the effectiveness of the official liability proceedings.

In the light of these findings, the Court considered that the German authorities did not afford the applicant sufficient redress for his treatment in breach of Article 3.

The Court concluded, by eleven votes to six, that the applicant could still claim to be the victim of a violation of Article 3 and that Germany had violated Article 3.

Article 6

As the Court had established in its case-law, the use of evidence obtained by methods in breach of Article 3 raised serious issues regarding the fairness of criminal proceedings. It therefore had to determine whether the proceedings against the applicant as a whole had been unfair because such evidence had been used.

The Court found that the effective protection of individuals from the use of investigation methods in breach of Article 3 may require, as a rule, the exclusion from use at trial of real evidence obtained as a result of a breach of that Article. It considered that this protection and a criminal trial’s fairness were only at stake however if the evidence obtained in breach of Article 3 had an impact on the defendant’s conviction or sentence.

In the present case, it was the applicant’s new confession at the trial – after having been informed that all his earlier statements could not be used as evidence against him – which formed the basis for his conviction and his sentence. The evidence in dispute had therefore not been necessary to prove him guilty or determine his sentence.

As regards the question whether the breach of Article 3 in the investigation proceedings had a bearing on the applicant’s confession during the trial, the Court observed that he had stressed in his statements at the trial that he was confessing freely out of remorse and in order to take responsibility for his offence, despite the threats uttered against him by the police. The Court therefore had no reason to assume that the applicant would not have confessed if the courts had decided at the outset to exclude the disputed evidence.

In the light of these considerations, the Court found that, in the particular circumstances of the case, the failure of the domestic courts to exclude the impugned evidence, secured following a statement extracted by means of inhuman treatment, had not had a bearing on the applicant’s conviction and sentence. As the applicant’s defence rights had been respected, his trial as a whole had to be considered to have been fair.

The Court concluded, by eleven votes to six, that there had been no violation of Article 6.

Article 41 (just satisfaction)

The applicant did not claim any award for pecuniary or non-pecuniary damage, but stressed that the objective of his application was to obtain a retrial. As there had been no violation of Article 6, the Court considered that there was no basis for the applicant to request a retrial or the reopening of the case before the domestic courts.

Three Property Rights Judgments

Last week, the European Court of Human Rights issued a number of important judgments which all evolve around the protection of property. In Sarica and Dilaver v. Turkey (available only in French), the Court held that the widespread practice in Turkey of de facto expropriation by the state represented a structural problem and was contrary to the Convention. This practice enabled the Turkish authorities to occupy property without any formal declaration of transferring ownership. They could also change the prospective use of the property irreversibly. The practice forced people to start Court proceedings in order to have such occupation of land quashed or in order to receive compensation. Under article 46 ECHR (binding force and execution of judgments) the Court indicated that Turkey should also take general measures in order to make the process of expropriation less unforeseeable and arbitrary and to secure compensation. Turkey should also actively discourage de facto expropriation by measures of deterrence and by holding the people responsible to account. Reforms in this area are thus now called for in Turkey.

The other two cases relate to a post-conflict context. In Saghinadze and others v. Georgia, the Court ruled on the eviction of an internally displaced person (IDP). The applicant, a Georgian who fled the Georgian province of Abkhazia during the armed conflict in the early 1990s, was given the use of a cottage in Georgia's capital Tbilisi by the Ministry of the Interior, by which he was employed. With his family he build up a new life there. Following the 'Rose Revolution' in Georgia in 2003, the applicant led a number of investigations into criminal cases and also submitted information to the authorities on abuse of power within the state apparatus. Apparently, he stepped on someone's toes a bit too hard, since he and his family were evicted from the cottage in 2004 by agents of the special forces. The Court found that both articles 8 (right to respect for the home) and Article 1 of Protocol 1 (protection of posessions) had been violated. The eviction had been unlawful under Georgian law and contrary specifically to the protection given to IDPs. In a particular example of very intense review, the European Court held that the Georgian Supreme Court had contradicted its on case-law in this matter. In para. 16 the Court noted on this that "where such manifestly conflicting rulings stem from the same jurisdiction, and no reasonable explanation is given for the divergence, such rulings smack of arbitrariness." The rule of law thus clearly also applies to the reasoning (or lack thereof) of national judgments themselves. One may note, in passing, that the Court lauds Georgia's inclusion in its laws of protection for IDPs in line with UN standards, but condemns its lack of application in the practice of this case.

Finally, the case of Dokic v. Bosnia and Herzegovina concerns the case of a lecturer at a military school who tried in vain to repossess his flat in Sarajevo which he had left at the start of the Bosnian war. He currently lives in Serbia and has both the Bosnian and Serb nationalities. Serbia intervened as a third party in the case. Interestingly, the Court considered it unnecessary to establish whether Dokic had been forced to flee Sarajevo, but noted that he was neither a refugee nor an IDP. This was irrelevant for the reasoning of the Court however, which in essence did not deal with the case as a war-related property issue (although that was part of the factual context), but rather decided within its general and established case-law on property rights. It held that Dokic was in essence treated differently than others on the basis of his ethnicity (Serb), even if the applicable law seemed neutral. In addition, the reasoning of the state that the housing was needed to accommodate other people in need was not supported by evidence (military flats were allocated to war veterans, but this was done irrespective of their housing situation or income). In addition, the applicant had not received a comparable occupancy right in Serbia as he had held in Bosnia - there was thus no equivalent alternative (as Bosnian law required). Finally, the compensation offered was too low in the view of the Court. Thus it concluded that Article 1 of Protocol 1 (P1-1) had been violated.

The European Court more strictly scrutinised the state's arguments than the former Bosnian Human Rights Commission had done. In deciding on the same case, the Commission in 2006 found no violation of P1-1. See the judgment (in Bosnian) here.

Finally, for those interested in housing rights (like myself) it is notable that the Court held that the case did not disclose an interference with the right to respect for the home (Art. 8 ECHR), since Dokic had shown no intention of returning to his former flat. This is an application of principles established in Demopoulos v. Turkey earlier this year and is an opposite situation (but same application) of older case law which stressed the need for continuing links with the dwelling at issue (e.g. Gillow v. United Kingdom).

See also the informative post(s) on this case here, by experts who have worked on housing restituion in practice in Bosnia.


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April 13, 2014

Tropical Cyclone Ita Leaves Queensland Behind

In their latest cyclone warning bulletin the Australian Government Bureau of Meteorology Tropical Cyclone Warning Centre in Brisbane revealed this forecast track for Tropical
Cyclone Ita:

Forecast track for Tropical Cyclone Ita at 7:57 pm EST Sunday 13 April 2014

Forecast track for Tropical Cyclone Ita at 7:57 pm EST Sunday 13 April 2014

The bulletin adds that:

Tropical Cyclone Ita is expected to maintain a southeast track as it crosses the Whitsunday Islands this evening before moving offshore away from the Queensland east coast overnight.

GALES with gusts to 90 kilometres per hour are possible between Bowen and Mackay this evening, before possibly extending further south to St Lawrence tonight and to Yeppoon early Monday. Gales should ease from the north tonight as the system begins to move offshore of the Queensland coast.

Heavy rainfall, which may lead to flash flooding, is expected to occur between Proserpine and Mackay, and should extend further south to Gladstone overnight. Rainfall totals of at least 100 to 200mm are likely and isolated falls to 400mm are possible.

As the system tracks near the coast abnormally high tides are expected between Proserpine and Mackay, but the sea level should not exceed the highest tide of the year. Large waves are likely along the foreshore.

People between Bowen and Yeppoon, including Mackay, should take precautions and listen to the next advice.

Here's how Ita looks from on high this morning, once again courtesy of  NASA Worldview and the Aqua satellite:

Tropical Cyclone Ita on Sunday 13 April 2014

Tropical Cyclone Ita on Sunday 13 April 2014

WeatherZone reports that there have still been no fatalities in Australia, although there have been some close calls:

Power blackouts and flooding continue across much of north Queensland in the wake of Cyclone Ita, as the storm system continues moving south. The category one system, which made landfall on Friday night, is tracking south of Townsville and is heading for Mackay. Falls of 400 millimetres were expected in some parts of the coast this afternoon, with Cyclone Ita expected to maintain tropical cyclone intensity as it moves south-east over the next 24 hours. Ken Kato from the Bureau of Meteorology (BOM) says conditions are still extreme. Wind gusts up to 90 kilometres per hour are expected this evening between Ayr and Mackay.

"Our warning also covers the possibility of abnormally high tides between Townsville and Mackay," he said.

The popular holiday destinations of Airlie Beach and the Whitsunday Islands were copping the brunt of Ita on Sunday afternoon, while the weather bureau advised residents from Bowen down to Yeppoon to prepare for flash flooding.  In Airlie Beach, four people had to be rescued from their car after becoming stranded. Swift water rescue crews arrived to find them sitting on the roof of the vehicle.

Meanwhile in other news from the Solomon Islands, and somewhat reminiscent of that from Haiti four years ago, the BBC reports that:

An earthquake of magnitude 7.6 has hit near the Solomon Islands, but there have been no reports of major damage or casualties.

The undersea quake was registered at a depth of 29km (18 miles), 100km (60 miles) south-east of Kira Kira.

A tsunami warning issued for the Solomon Islands, Papua New Guinea and New Caledonia was later cancelled.

Strong waves were reported after the earthquake struck at 07:14 on Sunday (20:14 GMT Saturday).

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« Links for 04-21-17 | Main | Trump's Tax Cut Plan Will... Pay... For... Itself! »

Friday, April 21, 2017

Paul Krugman: The Balloon, the Box and Health Care

If they persist in trying to fit the balloon in the box, eventually it will pop:

The Balloon, the Box and Health Care, by Paul Krugman, NY Times: Imagine a man who for some reason is determined to stuff a balloon into a box — a box that, aside from being the wrong shape, just isn’t big enough. He starts working at one corner, pushing the balloon into position. But then he realizes that the air he’s squeezed out at one end has caused the balloon to expand elsewhere. So he tries at the opposite corner, but this undoes his original work.
If he’s stupid or obsessive enough, he can spend a long time at this exercise, trying it from various different angles, and maybe even briefly convince himself that he’s making progress. But he’s kidding himself: No matter what he does, the balloon isn’t going to fit in that box.
Now you understand what’s happening to G.O.P. efforts to repeal and replace the Affordable Care Act.
Republicans have spent many years denouncing Obamacare as a terrible, horrible, no good law and insisting that they can do much better. They successfully convinced many voters that they could preserve the good stuff — the dramatic expansion of coverage that has brought the percentage of Americans without health insurance to a record low — while reducing premiums, shrinking deductibles and, of course, doing away with the taxes on high incomes that pay for the program.
Those promises basically define the box into which they’re trying to stuff health care. ...
Again and again, we read news reports to the effect that Republicans are closing in on a plan that will break the political deadlock..., the latest idea being floated, they’ll let insurance companies raise premiums on people with pre-existing conditions and compensate by creating special high-risk pools! ...
And because the task Republicans have set for themselves is basically impossible, their ongoing debacle over health care isn’t about political tactics or leadership..., this thing just can’t work. ...
All of this raises the obvious question: If Republicans never had a plausible alternative to Obamacare, if this debacle was so inevitable, what was the constant refrain of “repeal and replace” all about?
The answer, surely, is that it began as a cynical ploy; at first, the Republicans hoped to kill health reform before it really got started. And now they’ve trapped themselves: They can’t admit that they have no ideas without, in effect, admitting that they were lying all along.
And the result is that they just keep trying to stuff the balloon into that box.

    Posted by on Friday, April 21, 2017 at 07:23 AM in Economics, Health Care, Politics | Permalink  Comments (262)

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Saturday, August 06, 2016

Crowds Are Stupid; Wisdom Is Solitary

Do you even get the feeling when you are online that in spite of Google's claims to order search results primarily according to quality, the good stuff is actually being concealed from you? If so, you will not be surprised to learn that unless you are running TOR and Tails, it is. Some critics of the way the web has been hijacked by a few technology corporations say as much as 96% of online content is inaccessible to Joe Ordinary and you (but not me, I had a long career in data networking; although I would not put the figure as high as 96% unless you use exclusively Google for search. 90% would probably be nearer.).

A few years ago, tired of hearing that idiotic dictum of  Bill Gates (the man who made 'not fit for purpose' an acceptable quality rating,) and other Silicon valley mind manipulation artists about The Wisdom Of Crowds, I posted online an essay, Shakeaspeare's Proud Loner and The Widom Of Crowds to explore this wisdom of crowds phenomenon.
It's good to see more and more people are thinking on the same lines.  Even if this writer is discussing Democratic and Republican Party political philosophies, if you are patient enough to read the whole article (linked at the end of this extract) he comes to some interesting conclusions about groupthink, and how opinion is manipulated.

from Zero Hedge

Submitted by Robert Gore via,

Have you ever won or lost a political argument? Have you or an opponent ever said: “Your facts and logic are overpowering, I have to concede that you’re right.” It’s never happened, has it? It doesn’t happen because politics has little to do with facts and logic. It’s anchored in emotions that take root in infancy and are so deeply ingrained they are undoubtedly part of humanity’s evolutionary code. No bond is more enduring than that between parent and child, and none is more laden with psychological baggage. While political argument will always be a frustratingly fruitless endeavor, you can at least understand why this is so, and perhaps avoid wasting your time.

The first lesson infants learn, evolutionarily hardwired, is that mom provides. She supplies the physical basics, and psychological sustenance as well. She smiles and coos, delighted by almost everything her baby does. “Mom,” as in mom and the apple pies she cooks, has a sacred, unrivaled place in the human conscious and subconscious. Insulting someone’s mother is an invitation to a fight. Whether you realize or admit it or not, the person that bore, gave birth, and nurtured you through childhood has a outsize presence in your psyche.

“Branding” is a marketing buzzword, but one of some intellectual value in a field littered with useless emissions. If you’re trying to sell something, you want consumers to associate your product or service with a simple but psychologically powerful concept. Food companies and restaurant chains sell healthy and delicious, or tie eating into warm memories. Purveyors of athletic clothes and footwear link themselves with athletic excellence. The fat blob swilling beer on the couch gets winded going to the refrigerator, but wears Nike sweats. Cosmetic and fashion companies peddle hope to millions of women and men who will never look like the models who show off the merchandise. Insurance and home security companies sell fear.

Read all Crowds Are Stupid, Wisdom Is Solitary  >>

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Watch or read mainstream news or get your info from celebrity gossip websites and you could be forgiven for believing that all media / showbiz celebs in the USA are devoted fans of the rent - boy president, Barack Hussein Obama and his anointed successor Hillary Clinton. It is not so ...

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