Kernrechtsfrage
Whether the Swiss mutual legal assistance request had to be refused under Art. 2 lit. a IRSG in connection with Art. 2 lit. b EUeR because the Ukrainian proceedings allegedly lacked an independent and impartial tribunal.
Extrahierter Entscheid
No refusal was required; the appellant did not show a concrete and serious risk that his own Ukrainian proceedings would violate minimum fair-trial guarantees.
Extrahierte Begründung
Although Ukraine’s institutions and judiciary still showed deficiencies, Europarat bodies had not sanctioned Ukraine and the appellant relied mainly on general criticism of the country rather than specific facts showing a personal risk of judicial dependence in his case.