28 O’HALLORAN AND FRANCIS v. THE UNITED KINGDOM JUDGMENT – DISSENTING OPINION OF JUDGE PAVLOVSCHI Secondly, there are cases concerning the use of incriminating information compulsorily obtained outside the context of criminal proceedings in a subsequent criminal prosecution (see Saunders, cited above, § 67, and I.J.L. and Others v. the United Kingdom, nos. 29522/95, 30056/96 and 30574/96, § 82-83, ECHR 2000-IX). However, it also follows from the Court’s case-law that the privilege against self-incrimination does not per se prohibit the use of compulsory powers to obtain information outside the context of criminal proceedings against the person concerned. For instance, it was not suggested in Saunders that the procedure whereby the applicant was requested to answer questions on his company and financial affairs, with a possible penalty of up to two years’ imprisonment, in itself raised an issue under Article 6 § 1 (see Saunders, ibid.; see also I.J.L. and Others, cited above, § 100). Moreover, in a recent case the Court found that a requirement to make a declaration of assets to the tax authorities did not disclose any issue under Article 6 § 1, although a penalty was attached to a failure to comply and the applicant was actually fined for making a false declaration. The Court noted that there were no pending or anticipated criminal proceedings against the applicant and the fact that he may have lied in order to prevent the revenue authorities from uncovering conduct which might possibly lead to a prosecution did not suffice to bring the privilege against self-incrimination into play (see Allen v. the United Kingdom (dec.), no. 76574/01, ECHR 2002-VIII). Indeed, obligations to inform the authorities are a common feature of the Contracting States’ legal orders and may concern a wide range of issues (see for instance, as to the obligation to reveal one’s identity to the police in certain situations, Vasileva v. Denmark, no. 52792/99, § 34, 25 September 2003). Furthermore, the Court accepts that the right to silence and the right not to incriminate oneself are not absolute; hence, for instance, the drawing of inferences from an accused’s silence may be admissible (see Heaney and McGuinness, cited above, § 47, with a reference to John Murray, cited above, § 47). Given the close link between the right not to incriminate oneself and the presumption of innocence, it is also important to reiterate that Article 6 § 2 does not prohibit, in principle, the use of presumptions in criminal law (see Salabiaku v. France, 7 October 1988, § 28, Series A no. 141, and Weh, cited above). To this recapitulation some more rules could be added: In Jalloh, the Court adopted what appears to be a wholly new approach to self-incrimination. For the first time, it considered the following factors: (a) the nature and degree of compulsion used to obtain the evidence; (b) the weight of the public interest in the investigation and punishment of the offence in issue; (c) the existence of any relevant safeguards in the