Question juridique clé
Whether the administrative disciplinary procedure had a criminal or civil character under Article 6 ECHR, requiring a hearing
Solution extraite
No. The disciplinary regime for lawyers is administrative, not criminal, and the fine did not determine any civil rights or duties.
Motifs extraits
The court applied the autonomous Strasbourg criteria and held that lawyer discipline protects the public and the administration of justice, not penal interests; the relatively modest fine did not change that.