Question juridique clé
Whether the cantonal disciplinary fine violated Article 6 ECHR because the deciding body was not a court
Solution extraite
The disciplinary fine did not fall within Article 6 ECHR; the nature of the sanction was administrative, not criminal, and the case was neither about civil rights nor a criminal charge.
Motifs extraits
A mere disciplinary fine for breach of professional duties does not restrict the right to practise law and is not punitive in the criminal-law sense.