ANGUELOVA v. BULGARIA JUDGMENT 31 “1. Everyone has the right to liberty and security of person. No one shall be deprived of his liberty save in the following cases and in accordance with a procedure prescribed by law: ... (c) the lawful arrest or detention of a person effected for the purpose of bringing him before the competent legal authority on reasonable suspicion of having committed an offence or when it is reasonably considered necessary to prevent his committing an offence or fleeing after having done so; ...” 152. The applicant stated that it was absurd to consider – as the Government did – that the statutory 24-hour time-limit for police detention ran from the moment when the arrested person's identity was established. No such rule existed under Bulgarian law. Any detention without a written order was in violation of section 35 of the National Police Act. Furthermore, in the present case the police officers recognised Mr Zabchekov right away and addressed him by name. 153. The Government submitted that at the time he was taken to the police station Mr Zabchekov had not been a “detained person” within the meaning of section 35 of the National Police Act as his identity had not been known. It had been necessary to await his sobering up to allow his identification and decide whether detention was necessary. Therefore, a written order for his detention was not required. Such an order could not be issued in respect of a person whose identity was unknown. The Government further stated that the material legal conditions for a lawful detention had existed in any event: Mr Zabchekov had been apprehended while trying to steal and had been taken to the police station for identification. 154. The Court reiterates that the expressions “lawful” and “in accordance with a procedure prescribed by law” in Article 5 § 1 of the Convention essentially refer back to national law and state the obligation to conform to the substantive and procedural rules thereof. They require in addition that any deprivation of liberty should be consistent with the purpose of Article 5, namely to protect the individual against arbitrariness. The Court must moreover ascertain whether domestic law itself is in conformity with the Convention, including the general principles expressed or implied therein (see, among other authorities, Grauslys v. Lithuania, no. 36743/97, § 39, 10 October 2000). The unacknowledged detention of an individual is a complete negation of the fundamentally important guarantees contained in Article 5 of the Convention and discloses a most grave violation of that provision. The absence of a record of such matters as the date, time and location of detention, the name of the detainee, the reasons for the detention and the