Question juridique clé
Whether the cantonal court correctly refused to hear the criminal appeal as time-barred
Solution extraite
Yes. The appeal was filed after expiry of the applicable time limit because the dispositive had been validly served by postal collection notice and the appellant had no sufficient justification for not collecting it.
Motifs extraits
The appellant knew of the hearing and the importance of deadlines. His claimed confusion of dates and hospitalization did not justify his failure to act, and he could have informed the court or arranged collection of the mail. Normal-post service was not necessary.