Last Updated on June 27, 2019 by LawEuro
FIRST SECTION
DECISION
Application no. 20177/13
Izabela Julia Emilia CHŁAPOWSKA-TRZECIAK
against Poland
The European Court of Human Rights (First Section), sitting on 26 June 2018 as a Committee composed of:
Aleš Pejchal, President,
Krzysztof Wojtyczek,
Jovan Ilievski, judges,
and Abel Campos, Section Registrar,
Having regard to the above application lodged on 11 March 2013,
Having deliberated, decides as follows:
THE FACTS
1. The applicant, Ms Izabela Julia Emilia Chłapowska-Trzeciak, is a Polish national who was born in 1948 and lives in Warsaw. She was represented before the Court by Mr. R. Darabasz, a lawyer practising in Warsaw.
A. The circumstances of the case
2. The facts of the case, as submitted by the applicant, may be summarised as follows.
1. Background to the case
3. In 1944 the Polish Committee of National Liberation (Polski Komitet Wyzwolenia Narodowego) issued two decrees relating to nationalisation of agricultural land and forests (“the 1944 decrees”): the Decree on agrarian reform of 6 September 1944 (dekret o reformie rolnej) (“the agrarian decree”) and the Decree on the nationalisation of certain forests of 12 December 1944 (dekret o przejęciu niektórych lasów na własność Skarbu Państwa) (“the forest decree”) (see paragraphs 48-51 below).
4. Before the Second World War the applicant’s parents, Z. and C. Ch., were the owners of three estates: Stawiany, Pawłowo Skockie and Ciesle. Each estate included a park, a palace complex, farmland and forests. In 1946 the property was taken over by the State Treasury pursuant to the provisions of the 1944 decrees.
2. Proceedings for annulment of the expropriation measure
5. On 15 October 2007 the applicant asked the Wielkopolski Governor (Wojewoda Wielkopolski) to decide that the Stawiany, Pawłowo Skockie and Cieśle estates had not fallen within the scope of the agrarian decree.
6. Following a number of administrative decisions and appeals, the proceedings were eventually discontinued by the decisions of the Wielkopolski Governor of 24 March, 8 April, 21 April and 30 April 2010. The governor considered that the issue of whether or not the estates had fallen within the scope of agrarian decree should be examined by the civil courts.
3. The applicant’s attempts to recover the property and/or to obtain compensation
(a) Stawiany and Pawłowo Skockie estates
7. On an unknown date in February 2009 the applicant lodged a statement of claim with the Poznan Regional Court seeking compensation for the allegedly unlawful nationalisation of her father’s property (estates Stawiany and Pawłowo Skockie).
8. On 2 February 2011 the claims relating to compensation for forest land were severed to separate sets of proceedings (see paragraphs 13-16 and 17-20 below).
9. On 23 May 2011 the Poznan Regional Court gave judgment and dismissed the applicant’s claim. The court held that even if it were for a civil court to decide whether or not the property in question had fallen within the scope of the agrarian decree, the present claim was in any event time-barred. The basis for the applicant’s claim was the Law of 15 November 1956 on the State’s liability for damage caused by public servants (Ustawa o odpowiedzialności Skarbu Państwa za szkody wyrządzone przez Funkcjonariuszów państwowych) (“the 1956 Act”). The court confirmed that while, until at least 4 June 1989, that is the fall of the communist regime, claims for compensation could not have been effectively vindicated, there were no obstacles to pursuing such claims after that date. Nevertheless, the applicant had lodged her application with the Wielkopolski Governor only in 2007 (see paragraph 5 above). She had further lodged a claim with a civil court in 2009. Even assuming that a ten‑year prescription time-limit was applicable to the present proceedings, the applicant’s claims had become time-barred on 4 June 1999. For that reason the court refrained from examining whether or not the Pawłowo Skockie and Stawiany estates had fallen within the scope of the agrarian decree.
10. On 13 December 2011 the Poznan Court of Appeal upheld the first‑instance judgment. The court endorsed the findings of the Regional Court. It confirmed that, in principle, it was for the administrative authorities to decide whether or not the property in question had fallen within the scope of the 1944 decrees. However, according to the Supreme Court’s judgment of 6 October 2010 (II CSK 174/10), when there was no such administrative decision, a civil court could not avoid deciding the matter. However, the applicant had only generally questioned the legality of the agrarian decree. In that respect the court found that the applicant’s claims were not clearly set out. She had initially asked for restitution of the property in question but eventually confirmed that her claim had concerned only compensation. In the court’s view the applicant had failed to specify clearly the legal and factual grounds for her compensation claims. For that reasons her claim had to be dismissed.
11. On 15 January 2013 the Supreme Court refused to entertain the applicant’s cassation appeal.
12. The applicant’s subsequent attempts to reopen the proceedings were unsuccessful.
(b) Pawłowo Skockie forests
13. The claim for compensation for the nationalisation of forest land belonging to the Pawłowo Skockie estate was severed from the main set of proceedings on 2 February 2011 (see paragraph 8 above). In her pleadings the applicant relied on Article 417 of the Civil Code and section 7 of the Act of 6 July 2001 on the preservation of the national character of the country’s strategic natural resources (ustawa o zachowaniu narodowego charakteru strategicznych zasobów naturalnych kraju – “2001 Act”) (see paragraph 54 below).
14. On 23 May 2011 the Poznan Regional Court dismissed the applicant’s claim. The court held that section 7 of the 2001 Act was of a very general nature and could not constitute the basis for a compensation claim. It further considered that the plaintiff’s liability could only be based on the 1956 Act. However, relying on the same grounds as set out in the judgment given in the case relating to the Stawiany and Pawłowo Skockie estates (see paragraph 9 above), the court concluded that the applicant’s claims had become time-barred on 4 June 1999.
15. On 28 October 2011 the Poznan Court of Appeal dismissed the applicant’s appeal and endorsed the findings of the Regional Court. The court held that the 1944 decrees were binding legal acts. Pursuant to these decrees, ownership of land was transferred to the State Treasury ex lege. In view of the surface area of the Pawłowo Skockie estate, it was nationalised pursuant to section 2 § 1 (e) of the agrarian decree. The forest land was also taken over by the State in accordance with the law. The relevant entry in the land register had been made in 1946 and was of a declaratory character. The applicant could only have based her claim on the 1956 Act. However, she had failed to demonstrate that the nationalisation of the property in question was unlawful.
16. On 22 November 2012 the Supreme Court refused to admit the applicant’s cassation appeal.
(c) Stawiany forests
17. On 20 January 2010 the applicant lodged a statement of claim for compensation against the State Treasury – Durowo Forest Inspectorate for allegedly unlawful nationalisation of forest land belonging to the Stawiany estate. She further modified her claim and sought restitution of the forest in question or alternatively payment of compensation.
18. On 13 December 2011 the Poznan Regional Court gave judgment and dismissed her claim. In its reasoning the Regional Court made note of the following points. The 1944 decrees had been binding legal acts. Under section 2 § 1 (e) of the agrarian decree and section 1 § 3 (b) of the forest decree, ownership of land was transferred to the State Treasury ex lege. Due to its size, the Stawiany estate was nationalised under section 2 § 1 (e) of the agrarian decree. It was clear that the forest land which had belonged to that estate had also been taken over by the State in accordance with the law. The relevant entry in the land register had been made in 1946 and was of a declaratory character. The legal situation disclosed in the land register was in line with the property’s actual legal status and thus justified dismissing the claim for restitution of land.
19. The court further explained that for various reasons the plaintiff could not have based her compensation claim on the provisions of the Constitution or any other legal acts. Since the applicant had based her claim on the State’s liability in tort, the relevant provisions applicable to her situation were the provisions of the 1956 Act. However, pursuant to these regulations, the applicant had to demonstrate that she had suffered damage on account of unlawful action of public officials and that the forest land of the Stawiany estate had been taken over unlawfully. In the court’s view, the applicant had failed to prove that the expropriation of the forest land in question had been unlawful. It concluded that, even assuming that the applicant had had any claim for compensation, such claim in any event had become time-barred on 4 June 1999.
20. On 3 July 2012 the Poznań Court of Appeal dismissed the applicant’s claim and fully endorsed the Regional Court’s findings. It concluded that there was no unlawful action on the part of the public officials in the process of taking over the forest land belonging to the Stawiany estate and consequently no State liability in tort had arisen in the present case.
21. On 20 September 2013 the Supreme Court dismissed the applicant’s cassation appeal. The court confirmed that the forest land belonging to the Stawiany estate had been taken over in accordance with the relevant provisions of the 1944 Decrees. It further reiterated that the 1944 Decrees had not provided for payment of any compensation for nationalised property. Therefore, the courts of first and second instance had correctly held that the applicant did not have any claim for compensation. The Supreme Court concluded that any findings about the prescription of time‑limits were groundless, since a claim that had not arisen could not become time-barred.
(d) Proceedings for amending the land register (Stawiany and Pawłowo Skockie forests)
22. On an unknown date in 2012 the applicant lodged a civil action against the State Treasury with the Wągrowiec District Court. She requested that steps be taken by that court to put right the discrepancies between the entry in the land register and the actual ownership of the plots (powództwo o uzgodnienie ksiçgi wieczystej z rzeczywistym stanem prawnym). She referred to the forest land which had previously belonged to the Stawiany and Pawłowo Skockie estates.
23. On 4 October 2012 the court gave judgment and dismissed the applicant’s claim.
24. On 5 July 2013 the Poznań Regional Court quashed this judgment and remitted the case. The court noted that the District Court had failed to establish whether the forests belonging to the Pawłowo Skockie and Stawiany estates could have been taken over by the State pursuant to the provisions of the agrarian decree.
25. On 22 November 2013 the Supreme Court quashed the Regional Court’s judgment.
26. Subsequently, the applicant asked the Wielkopolski Governor to declare that the forest land belonging to the Pawłowo Skockie and Stawiany estates had not been taken over by the State pursuant to the provisions of the agrarian decree. On 29 May 2014 the Wielkopolski Governor gave a decision and held that the forest land in question had not fallen within the scope of the agrarian decree. On 28 October 2014 the Minister of Agriculture upheld this decision. It further explained that the administrative authorities were only competent to declare whether the land had been taken over pursuant to the provisions of the agrarian decree. However, it was for the civil courts to determine whether it could have been taken over in accordance with the forest decree.
27. On 28 April 2015 the Poznań Regional Court stayed the appeal proceedings relating to the amendments in the land register.
28. The applicant failed to submit any further information concerning this set of proceedings.
(e) Ciesle estate
29. On 7 November 2008 the applicant lodged a statement of claim with the Poznan Regional Court seeking, inter alia, restitution of the Cieśle estate, which had belonged to her father.
30. On 8 July 2009 the Poznań Regional Court dismissed her claim on the ground that she had not demonstrated that the Cieśle estate had been taken over by the State unlawfully. The applicant’s appeal was dismissed by the Poznan Court of Appeal on 3 December 2009. The court upheld the findings made by the Regional Court.
31. On 6 October 2010 the Supreme Court quashed the Court of Appeal’s judgment. The court held, referring to the Constitutional Court’s judgment of 1 March 2010 (P 107/08) that when there was no administrative decision relating to whether an estate had fallen within the scope of the agrarian decree, a civil court should decide on the matter. The court also reiterated the well-established view of the Constitutional Court and the Supreme Court that, while the 1944 decrees were disgraceful, (niegodziwe) they had created permanent consequences in the area of property rights.
32. On 13 January 2011 the Poznan Court of Appeal quashed the Poznan Regional Court’s judgment of 8 July 2009. The court held that the Regional Court had failed to establish whether the Cieśle estate had fallen within the scope of the agrarian decree.
33. On 20 September 2011 the applicant had eventually specified her claim. She asked the Regional Court to give a declaratory judgment that the Cieśle estate had not fallen within the scope of the agrarian decree. She had further requested restitution of the land belonging to the Cieśle estate. Alternatively, if the court did not allow these claims, she asked for compensation from the State Treasury.
34. On 23 January 2012 the Poznań Regional Court gave judgment and dismissed the applicant’s claims. The court reiterated the established case‑law of the domestic courts that the provisions of the agrarian decree had formed part of the legal order and therefore could have been a basis for the State to take over the property. The Cieśle estate (the palace, park and farmland) had formed the so-called “land property” (nieruchomość ziemska) for the purposes of the agrarian decree. In the court’s view the palace and the surrounding park had functional and economic links with the farmland. Given the property’s surface area, it had fallen within the scope of the agrarian decree. The estate had been taken over ex lege, without compensation, on the date of entry into force of the agrarian decree. There had been no need to issue an administrative decision on the matter. Consequently, since the State Treasury remained the owner of the estate, the applicant’s claims for restitution and a declaratory judgment had to be dismissed.
35. With regard to the applicant’s claim for compensation, the court held that there was no need to examine the substantive grounds for any such claim, since in any event it had become time-barred on 31 December 1999 at the latest.
36. On 24 May 2012 the Poznan Court of Appeal amended the first‑instance judgment. The court held that the palace and park belonging to the Cieśle estate had not been taken over by the State pursuant to the provisions of the agrarian decree. It explained that the palace and the surrounding park had not had any functional and economic links with the farmland. Consequently, they had not fallen within the scope of the agrarian decree.
37. The Court was further of the view that the applicant’s claim for restitution could not be allowed since the property in question was managed by the Agricultural Property Agency (Agencja Nieruchomości Rolnych), which had not been summoned to participate in the proceedings as a defendant.
38. Lastly, the court noted that compensation claims could only be examined with respect to the part of the property that had been taken over by the State, despite the fact that it had not fallen within the scope of the agrarian decree. However, the applicant had meanwhile lodged a claim for amending the land register in accordance with the legal situation and she could still recover the property. Therefore, the present claim was premature.
39. The court also agreed with the findings made by the Regional Court with respect to prescription of the claim for compensation.
40. On 23 October 2012 the Poznan Court of Appeal rejected the applicant’s cassation appeal on procedural grounds. Her further interlocutory appeal was dismissed by the Supreme Court on 21 March 2013.
(f) Proceedings for amending the land register (Ciesle)
41. On 2 October 2008 the applicant lodged a civil action against the State Treasury, statio fisci Regional Direction of Water Management in Poznań (Regionalny Zarząd Gospodarki Wodnej w Poznaniu) and the Agricultural Property Agency, with the Grodzisko Wielkopolskie District Court. She requested that steps be taken by that court to put right the discrepancies between the entry in the land register and the actual ownership of the plot.
42. On 10 March 2011 the court gave judgment and dismissed the applicant’s claim.
43. On 1 February 2013 the Poznan Regional Court quashed this judgment and remitted the case. The court referred to the declaratory judgment given by the Poznan Court of Appeal on 24 May 2012 (see paragraphs 36-39 above) in which it had been established that the palace and the park belonging to the Ciesle estate had not been taken over by the State pursuant to the provisions of the agrarian decree.
44. On 20 September 2013 the Supreme Court dismissed the defendant’s interlocutory appeal.
45. On 11 December 2015 the Grodzisko Wielkopolskie District Court discontinued the proceedings as meanwhile the applicant had withdrawn her statement of claim.
(g) Further developments
46. On 19 October 2015 the applicant informed the Agricultural Property Agency in Poznań that she had intended to exercise her right of pre-emption in respect of part of the agricultural land which had belonged to the Cieśle estate (surface area of 261 ha).
47. On 11 January 2016 the applicant and two other heirs of the former owners bought the land in question for a total sum of 16,009,200 Polish zlotys (PLN).
B. Relevant domestic law and practice
1. The 1944 Decrees
48. In 1944 the Polish Committee of National Liberation issued two decrees providing for nationalisation of agricultural and forest land.
(a) Decree on agrarian reform
49. On 6 September 1944 the Decree on agrarian reform was issued. It provided that properties of an agricultural nature, owned or co-owned by natural or legal persons, with an area exceeding 100 ha in total or 50 ha of agricultural land, would be allocated for agrarian reform (section 2 § 1 (e)).
50. With regard to properties in the Pomeranian, Poznań or Silesian regions the area was set at 100 ha, regardless of the size of the agricultural property.
51. The decree further prescribed that properties would be transferred to the State Treasury immediately and without any compensation.
(b) Decree on the nationalisation of certain forests
52. On 12 December 1944 the Decree on the nationalisation of certain forests was issued. It provided that forests and forest land, owned or co‑owned by natural and legal persons, with an area exceeding 25 ha, would be transferred to the State Treasury.
2. State’s liability in tort
53. The relevant provisions of the Civil Code relating to the State’s liability in tort are set out in the Court’s decision in the case of Lubelska Fabryka Maszyn i Narzędzi Rolniczych ‘Plon’ and 2 other applications ((dec.) 1680/08, §§ 49-53, 3 October 2017).
3. Act of 6 July 2001 on the preservation of the national character of the country’s strategic natural resources (“the 2001 Act”)
54. A detailed description of the relevant provisions of the 2001 Act together with a summary of the domestic courts’ case-law appears in Zamoyski-Brisson and others ((dec.) no. 19875/13, §§ 39-42 and 45-55, 3 October 2017).
4. Legislative initiatives concerning restitution and compensation for property taken under the communist regime
55. The description of legislative initiatives aimed at enacting a restitution bill is provided in Lubelska Fabryka (cited above §§ 67-71); Ogórek v. Poland ((dec) no. 28490/03, §§ 53-60, 18 September 2012); and Pikielny v. Poland ((dec.) no. 3524/05 §§ 32-39, 18 September 2012).
COMPLAINTS
56. The applicant submitted several application forms on various dates between 11 March 2013 and 5 March 2014.
57. She complained in principle of a breach of Article 1 of Protocol No. 1 to the Convention on account of the fact that the State had failed to enact any compensation or restitution laws providing for restoration of property nationalised after the Second World War. She also referred to the fact that her claims for compensation for her legal predecessor’s property had been dismissed.
58. Relying on numerous provisions of the Convention, the applicant further complained under Article 14 of the Convention that she was discriminated against in the proceedings relating to her compensation claims; under Article 6 that the domestic courts committed errors of fact and law when dealing with her claims; under Article 13, that she had not had an effective domestic remedy in respect of her claims; that her late father was persecuted after the Second World War on account of his political views and finally that her family had suffered injustice under the communist regime.
THE LAW
A. Alleged violation of Article 1 of Protocol No. 1
1. Restitution laws
59. The applicant alleged under Article 1 of Protocol No 1 to the Convention that Poland had failed to enact restitution laws relating to compensation or restitution of property nationalised after the Second World War.
This provision reads as follows:
“Every natural or legal person is entitled to the peaceful enjoyment of his possessions. No one shall be deprived of his possessions except in the public interest and subject to the conditions provided for by law and by the general principles of international law.
The preceding provisions shall not, however, in any way impair the right of a State to enforce such laws as it deems necessary to control the use of property in accordance with the general interest or to secure the payment of taxes or other contributions or penalties.”
60. The Court has already held on many occasions that Article 1 of Protocol No. 1 to the Convention cannot be interpreted as imposing any general obligation on the Contracting States to return property which was transferred to them before they ratified the Convention. Nor does this provision impose any restrictions on the Contracting States’ freedom to determine the scope of property restitution or rehabilitation laws. The Convention imposes no specific obligation on them to provide redress for wrongs or damage caused prior to their ratification of the Convention (see Von Maltzan and Others v. Germany (dec.) [GC], nos. 71916/01 and 2 others, § 77, ECHR 2005‑V)).
61. Accordingly, the Polish State has no duty under Article 1 of Protocol No. 1 to the Convention to enact laws providing for restitution of nationalised property or compensation for the property lost by the applicant’s family (see Preussische Treuhand GmbH & CO. Kg A. A. v. Poland (dec.), no. 47550/06, 7 October 2008, §§ 63-64)
62. It follows that this complaint is incompatible ratione materiae with the provisions of the Convention and the Protocols thereto within the meaning of Article 35 § 3 and must be rejected pursuant to Article 35 § 4.
2. Proceedings for restitution and compensation
63. The applicant complained under Article 1 of Protocol No. 1 to the Convention that her claims for compensation and/or restitution of the nationalised property had been dismissed by the domestic courts.
64. The Court reiterates that where the proprietary interest is in the nature of a claim it may be regarded as an “asset” only where it has a sufficient basis in national law, for example where there is settled case-law of the domestic courts confirming it (see Kopecký v. Slovakia [GC], no. 44912/98, § 52, ECHR 2004‑IX).
65. The Court notes that the 1944 decrees provided for nationalisation of agricultural property and forest land. Pursuant to their provisions, the property was expropriated ex lege on the date of the decrees’ entry into force. Most importantly, the decrees did not provide for payment of any compensation for the seized property (see paragraphs 49-51 above).
66. To the present day the Polish State has not enacted any further pre- or post-ratification restitution or compensation laws providing for restoration of property expropriated pursuant to the 1944 decrees that might have generated a new property right eligible for protection under Protocol No. 1 (compare and contrast Broniowski v. Poland [GC], no. 31443/96, § 100, ECHR 2004‑V).
67. In respect of the Stawiany and Pawłowo Skockie estates, the Court observes that the domestic courts concluded that the applicant had no compensation or restitution claims under the domestic legislation (see paragraphs 9, 10 above).
68. The Court considers that this interpretation of the domestic law does not appear to have been arbitrary or manifestly unreasonable. Consequently, in view of its limited jurisdiction to interpret domestic law (see Jantner v. Slovakia, no. 39050/97, § 32, 4 March 2003), in the circumstances of the present case, it does not find it necessary to substitute its view for that expressed by the Polish courts.
69. Accordingly, in respect of the Stawiany and Pawłowo Skockie estates, the applicant had no claim under domestic law that could qualify as an “asset” protected under Article 1 of Protocol No. 1 (see Kopecký, cited above§ 52). This part of the application is therefore incompatible ratione materiae and must be rejected in accordance with Article 35 §§ 3 (a) and 4 of the Convention.
70. The Court further notes that the applicant’s claim for compensation and or restitution of the Stawiany and Pawłowo Skockie forest land was dismissed by the civil courts (see paragraphs 14-16 and 18-21 above). However, subsequently, the Wielkopolski Governor decided that the forest land belonging to those estates had not been taken over pursuant to the agrarian decree (see paragraph 26 above).
71. In addition, in respect of the Ciesle estate, the domestic court held that part of the property that is the park and palace complex, had not been taken over pursuant to the provisions of the agrarian decree (see paragraph 36 above).
72. The applicant has not adduced any evidence that under the domestic law those decisions were sufficient to give rise to a proprietary interest protected by Article 1 of Protocol No 1 to the Convention. In the Court’s view, even assuming that those decisions were sufficient to give rise to such a “proprietary interest” (see, mutatis mutandis, Krasnodębska‑Kazikowska and Łuniewskav. Poland, no. 26860/11, § 31, 6 October 2015) this part of the application is in any event inadmissible for the following reasons.
73. The Court observes that in the present case the proceedings before the domestic courts were conducted in an adversarial manner. There is no indication that the applicant was in any way prevented from submitting her evidence and/or developing legal arguments before the domestic courts. The applicant’s case was examined by the courts of three instances, including the Supreme Court. The Court considers that the domestic courts exhaustively addressed the applicant’s arguments and their decisions are sufficiently reasoned. Their interpretation of the domestic law does not appear to have been arbitrary or manifestly unreasonable. Consequently, noting that the applicant does not complain about any discrepancies in the domestic law and given that it is not the Court’s function to deal with errors of fact or law allegedly committed by a national court, unless and in so far as they may have infringed rights and freedoms protected by the Convention (see, inter alia, J.A. Pye (Oxford) Ltd and J.A. Pye (Oxford) Land Ltd v. the United Kingdom [GC], no. 44302/02, § 75, ECHR 2007‑III), the Court sees no reason to call into question the domestic courts’ decisions in this respect.
74. Finally, the Court observes that the applicant had failed to submit any information about the further course of the proceedings relating to the amendments in the land register in respect of the Stawiany and Pawłowo Skockie forests. In addition, it should be noted that the applicant withdrew her statement of claim in respect of the Ciesle estate and decided to exercise her right of pre-emption in order to acquire its ownership (see paragraphs 45-47 above).
75. It follows that this complaint is manifestly ill-founded and must, as such, be rejected in accordance with Article 35 §§ 3 (a) and 4 of the Convention.
B. Other alleged violations
76. The applicant also relied on Articles 6, 13 and 14 of the Convention and complained that the domestic courts had committed errors of fact and law, that she had not had an effective domestic remedy and that she was discriminated against. She also complained that her late father had been persecuted after the Second World War by the communist authorities on account of his political views.
77. The Court has examined those complaints. However, in the light of all the material in its possession, and in so far as the matters complained of are within its competence, the Court finds that there is no appearance of a violation of any of these Articles. It follows that this part of the application is manifestly ill-founded and must be rejected in accordance with Article 35 §§ 3 (a) and 4 of the Convention.
For these reasons, the Court, unanimously,
Declares the application inadmissible.
Done in English and notified in writing on 19 July 2018.
Abel Campos Aleš Pejchal
Registrar President
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