Question juridique clé
Whether the bankruptcy estate had standing to bring a criminal appeal and constitutional subsidiary appeal
Solution extraite
The bankruptcy estate lacked standing because it was only an injured party, not a victim within the LAVI, and it had no legally protected interest to challenge the dismissal on the merits.
Motifs extraits
A non-victim injured party generally cannot appeal on the merits in criminal matters. The bankruptcy estate, acting to maximize the dividend for creditors, alleged only economic harm and was not a private prosecutor under Geneva procedure. It could only complain of formal denial of justice, which was not shown because it had been heard by the chamber.