joinder of the case to other cases, (v) the intervention of other persons in the procedure . Therefore , a more complex case may justify longer proceedings.7 The European Court however Indicated that even in very complex cases unreasonable delays may still occur.8 140. In Ivan lovchev Petrov v. Bulgaria,9 the Applicant and a certain Mr S.V. were arrested in Sofia on suspicion of having stolen a car in 1990. They were charged and placed in pre-trial detention. In the beginning of 1991 , Mr S.V managed to escape during a transfer from one detention facility to another. In May 1991 , the Applicant was released on bail. On 24 July 1991 , the Applicant was arrested in Gabrovo on charges of theft. The case was joined to other cases pending against Mr S.V., some of which also concerned the applicant. On 5 February 1993, the proceedings were stayed as Mr S.V.'s whereabouts were unknown. According to the Applicant, Mr S.V. had settled in Greece, but during the following years had come back to Bulgaria every summer without ever having been stopped or bothered by the authorities , and had even renewed his identity documents. The Court concluded that it took altogether about 9 years for the matter to be disposed of. 141 . In determining whether or not the time was reasonable, the European Court held that " ... the case was factually complex, as it concerned numerous offences committed in different places. However, it does not appear that this was the principal reason for the delays in the investigation. Nor does it seem that the Applicant contributed in any way to the protraction of the proceedings, which was apparently mainly the result of the authorities ' inability to track down and summon his coaccused, Mr. S.V. The absence of a co-accused cannot justify a period of inactivity as long as the one obtaining in the present case, where almost no investigative actions were carried out for a period of about nine years, especially since, in view of See Boddaert v. Belgium (Application 12919/87) in wh ich a period of six years and three months was not considered unreasonable by the Court since 1t concerned a difficult murder enqUiry and the parallel progression of two cases. 8 See Ferantelli and Santangelo v. Italy (Application 19874/92) concerning a murder trral that took s1xteen years. 7 9 Application 1 51 97/02. 41

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