Key legal question
Whether the refusal to appoint ex officio defense counsel violated Art. 132 CPP.
Extracted holding
No. The case was not objectively difficult enough, and the appellant's personal abilities allowed him to defend himself in this simple proceeding.
Extracted reasoning
Court-appointed defense under Art. 132 CPP requires indigence and a justified need for defense. Although the qualification of breach of trust in a leasing context may raise legal questions, the appellant had university training, business experience, and could present the relevant facts himself. His foreign residence and limited finances did not show case complexity.