Article 6 § 1: Your Right to a Timely Judgment

Article 6 § 1 of the European Convention on Human Rights guarantees a fair hearing, publicly and within a reasonable time, before an independent and impartial tribunal. Most people read that as a rule about how trials are conducted. The ECHR reads it as something more: a rule about what a trial is for.

In Hornsby v. Greece, the Court held that Article 6 § 1 would be pointless if it protected only the right to a ruling, not the right to have that ruling enforced. Since then, the case law has consolidated: enforcement is inseparable from the trial itself. A judgment that never gets executed is, in Convention terms, no judgment at all.

This is why the ECHR has become an unlikely but effective forum for debt recovery against public bodies. When the debtor is a State organ, and domestic enforcement has failed, the delay itself becomes the breach. Time is not neutral — and the Convention is explicit that it can amount to a violation of the right protected under Article 6 § 1.