O’HALLORAN AND FRANCIS v. THE UNITED KINGDOM JUDGMENT 15 Proceeds of Crime (Northern Ireland) Order 1996. He did not attend an interview to give the information, and was fined. Although the applicant was acquitted in the underlying proceedings against him for false accounting and conspiracy to defraud arising from the same set of facts, the Court concluded that it was open to the applicant to complain of an interference with his right not to incriminate himself. As to a justification for the coercive measures, the Court noted that not all coercive measures gave rise to a conclusion of an unjustified interference with the right not to incriminate oneself. The Court found that neither the security context nor the available procedural protection could justify the measures in the case (see Shannon, cited above, §§ 26-40). 52. Jalloh v. Germany ([GC], no. 54810/00, ECHR 2006-IX) concerned the use of evidence in the form of drugs swallowed by the applicant, which had been obtained by the forcible administration of emetics. The Court considered the right to remain silent and the privilege against selfincrimination in the following terms: “94. ... While Article 6 guarantees the right to a fair hearing, it does not lay down any rules on the admissibility of evidence as such, which is primarily a matter for regulation under national law (see Schenk v. Switzerland, 12 July 1988, §§ 45-46, Series A no. 140, and Teixeira de Castro v. Portugal, 9 June 1998, § 34, Reports 1998-IV). ... 100. As regards the use of evidence obtained in breach of the right to silence and the privilege against self-incrimination, the Court recalls that these are generally recognised international standards which lie at the heart of the notion of a fair procedure under Article 6. Their rationale lies, inter alia, in the protection of the accused against improper compulsion by the authorities, thereby contributing to the avoidance of miscarriages of justice and to the fulfilment of the aims of Article 6. The right not to incriminate oneself, in particular, presupposes that the prosecution in a criminal case seek to prove their case against the accused without resort to evidence obtained through methods of coercion or oppression in defiance of the will of the accused (see, inter alia, Saunders, cited above, § 68; Heaney and McGuinness, cited above, § 40; J.B. v. Switzerland, no. 31827/96, § 64, ECHR 2001-III; and Allan [v. the United Kingdom, no. 48539/99], § 44[, ECHR 2002-IX]). 101. In examining whether a procedure has extinguished the very essence of the privilege against self-incrimination, the Court will have regard, in particular, to the following elements: the nature and degree of the compulsion, the existence of any relevant safeguards in the procedures and the use to which any material so obtained is put (see, for example, Tirado Ortiz and Lozano Martin v. Spain (dec.), no. 43486/98, ECHR 1999-V; Heaney and McGuinness, cited above, §§ 51-55; and Allan, cited above, § 44). 102. The Court has consistently held, however, that the right not to incriminate oneself is primarily concerned with respecting the will of an accused person to remain silent. As commonly understood in the legal systems of the Contracting Parties to the Convention and elsewhere, it does not extend to the use in criminal proceedings of