52
GUZZARDI v. ITALY JUDGMENT
DISSENTING OPINION OF JUDGE BINDSCHEDLER-ROBERT
DISSENTING OPINION OF JUDGE BINDSCHEDLERROBERT
(Translation)
The Court considered that it had to reject the preliminary objection based
on non-exhaustion of domestic remedies and conclude, as regards the merits
of the case, that there had been a violation of Article 5 (art. 5) of the
Convention. I regret that I disagree with the majority of my colleagues on
these two points. I shall endeavour to set out as briefly as possible the
reasons for my dissent.
1. As regards the exhaustion of domestic remedies, I should like to take
the liberty of making a preliminary observation to which I attach
importance. The judgment applies to the proceedings on appeal and in
cassation, in other words to the domestic proceedings, the principle that the
rule of exhaustion must be interpreted "with a certain degree of flexibility
and without excessive regard for matters of form" (§ 72). This principle is
certainly correct if one applies it to the international rule itself when one is
in the process of determining its scope. On the other hand, to apply it to
domestic law in order to determine and interpret the conditions laid down
there under in the matter of remedies amounts to endowing the international
court with jurisdiction to interpret that law and, in the final analysis, to base
itself on a domestic law that does not exist. Reference back to domestic law
by the rule of exhaustion of domestic remedies can only mean a reference
back to that law as interpreted by domestic case-law [see, on this point,
Jacobs, The European Convention on Human Rights, Oxford, 1975, p. 240].
I thus conclude that there was no call to enquire whether "in the Court’s
view" the pleas advanced by the applicant on appeal and in cassation were
equivalent to an allegation of a breach of the right to individual liberty.
What should have been done, in my view, was to determine whether, in the
light of Italian legislation and case-law, Mr. Guzzardi had exercised such
remedies and adduced such arguments as were capable of leading to the
reversal of the decision he was challenging. I would add that the case-law of
the Court and the Commission relied on by the judgment in support of its
extensive interpretation definitely does not corroborate that interpretation;
indeed, in each of the cases mentioned the principle that the rule of
exhaustion of domestic remedies should be flexibly interpreted concerns the
scope of the international obligation and not the interpretation of domestic
law.
Having said that and turning now to the question whether or not remedies
were exhausted in this particular case, I cannot do better than to refer to the
dissenting opinion of the President, Mr. Balladore Pallieri, the national
judge, with which I entirely agree.
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