{"id":5702,"date":"2019-05-26T15:29:22","date_gmt":"2019-05-26T15:29:22","guid":{"rendered":"https:\/\/laweuro.com\/?p=5702"},"modified":"2020-10-03T16:42:28","modified_gmt":"2020-10-03T16:42:28","slug":"case-of-cristian-catalin-ungureanu-v-romania-european-court-of-human-rights","status":"publish","type":"post","link":"https:\/\/laweuro.com\/?p=5702","title":{"rendered":"CASE OF CRISTIAN CATALIN UNGUREANU v. ROMANIA (European Court of Human Rights)"},"content":{"rendered":"<p style=\"text-align: center;\">FOURTH SECTION<br \/>\nCASE OF CRISTIAN C\u0102T\u0102LIN UNGUREANU v. ROMANIA<br \/>\n(Application no. 6221\/14)<\/p>\n<p style=\"text-align: center;\">JUDGMENT<br \/>\nSTRASBOURG<br \/>\n4 September 2018<\/p>\n<p style=\"text-align: center;\">FINAL<br \/>\n04\/12\/2018<\/p>\n<p>This judgment has become final under Article 44 \u00a7 2 of the Convention. It may be subject to editorial revision.<\/p>\n<p><strong>In the case of Cristian C\u0103t\u0103lin Ungureanu v. Romania,<\/strong><\/p>\n<p>The European Court of Human Rights (Fourth Section), sitting as a Chamber composed of:<\/p>\n<p>Ganna Yudkivska, President,<br \/>\nVincent A. De Gaetano,<br \/>\nPaulo Pinto de Albuquerque,<br \/>\nEgidijus K\u016bris,<br \/>\nIulia Motoc,<br \/>\nGeorges Ravarani,<br \/>\nP\u00e9ter Paczolay, judges,<br \/>\nand Marialena Tsirli, Section Registrar,<\/p>\n<p>Having deliberated in private on 3 July 2018,<\/p>\n<p>Delivers the following judgment, which was adopted on that date:<\/p>\n<p><strong>PROCEDURE<\/strong><\/p>\n<p>1.\u00a0\u00a0The case originated in an application (no. 6221\/14) against Romania lodged with the Court under Article 34 of the Convention for the Protection of Human Rights and Fundamental Freedoms (\u201cthe Convention\u201d) by a Romanian national, Mr Cristian C\u0103t\u0103lin Ungureanu (\u201cthe applicant\u201d) on 25\u00a0November\u00a02013.<\/p>\n<p>2.\u00a0\u00a0The applicant was represented by Ms E. Ungureanu, a lawyer practising in Ploie\u015fti. The Romanian Government (\u201cthe Government\u201d) were represented by their Agent, Ms C. Brumar, from the Ministry of Foreign Affairs.<\/p>\n<p>3.\u00a0\u00a0The applicant alleged that it had been impossible for him to maintain personal relations with his son during the divorce proceedings, and that the length of those proceedings had been excessive.<\/p>\n<p>4.\u00a0\u00a0On 16 September 2014 the application was communicated to the Government.<\/p>\n<p><strong>THE FACTS<\/strong><\/p>\n<p>I.\u00a0\u00a0THE CIRCUMSTANCES OF THE CASE<\/p>\n<p>5.\u00a0\u00a0The applicant was born in 1972 and lives in Ploie\u0219ti.<\/p>\n<p>6.\u00a0\u00a0At the relevant time, he was married to I.M.U. and they had a son together, born in 2006. Following a series of conflicts between the parents concerning their son\u2019s education, on 13 September 2012 I.M.U. filed for divorce and custody of the child. On 19 October 2012 she left the family home and took the child with her. They moved in with her parents and grandmother.<\/p>\n<p>7.\u00a0\u00a0On 2 November 2012 the applicantlodged an application for aninterim injunction (ordonan\u0163\u0103 pre\u015feden\u0163ial\u0103), seeking to be granted sole or shared custody of the child during the divorce proceedings, or alternatively the right to visit the child during those proceedings according to a detailed schedule that he submitted to the court.<\/p>\n<p>8.\u00a0\u00a0The Ploie\u0219ti District Court gave its ruling on 8 January 2013. It ruled that it would not be in the child\u2019s interests to change his residence temporarily during the divorce proceedings. It also observed that the applicant had not been prevented from visiting his child in the mother\u2019s new home, as he himself had confirmed in his statements before the court. The court noted that in any case the law did not provide for the possibility to have visiting rights established during divorce proceedings. It relied on Article\u00a06132of the Code of Civil Procedure (see paragraph 18 below).<\/p>\n<p>9.\u00a0\u00a0Following an appeal by the applicant, that ruling was upheld by the Prahova County Court, which rejected all the arguments raised by the applicant concerning his right to visit his child. The court reiterated that the law did not allow for the granting of that right during divorce and custody proceedings. The court also ordered the applicant to pay 1,000\u00a0Romanian lei (RON \u2013 approximately 230 euros (EUR)) to I.M.U., representing the costs that I.M.U. had incurred. The court delivered the final decision in the case on 27May 2013.<\/p>\n<p>10.\u00a0\u00a0In June 2013 the applicant, who was in the habit of visiting his son at school in the mornings, was removed from the school premises by the school guard, who informed him that from then on, he would need the school principal\u2019s permission if he wanted to see his son at the school.<\/p>\n<p>11.\u00a0\u00a0According to the applicant, after the final decision of 27\u00a0May\u00a02013 (see paragraph 9 above), I.M.U. and her family denied him any further contact with his son. It appears from the parties\u2019 submissions that the applicant was able to see his son on 27 December 2012, between 31\u00a0December\u00a02012 and 2 January 2013, on 20 January, between 2 and 3\u00a0March, on 14 and 17 March, on 28 April, on 2, 6 and 12 May 2013,and one last time, on 9 June 2013, after the court had given its ruling in respect of the interim injunction.<\/p>\n<p>12.\u00a0\u00a0On 30 October 2013 the applicant added a copy of the District Court\u2019s ruling of 8 January 2013 (see paragraph 8 above) to the case file.<\/p>\n<p>13.\u00a0\u00a0After several postponements that were due mainly to the parties\u2019 requests to be allowed to submit additional evidence, on 22\u00a0January\u00a02014 the Ploie\u015fti District Court gave its judgment on the divorce proceedings, ruling that the child\u2019s sole residence would be with his mother. The applicant was granted the right to have the child stay at his home every other weekend and for two weeks during the summer holidays. On 21\u00a0February\u00a02014 the applicant asked the District Court to finish the drafting of its written judgment faster, and reiterated that he had been unable to see his child for the past ten months.<\/p>\n<p>14.\u00a0\u00a0On 4 March 2014 the judgment was served on the applicant at his address; on 28 March 2014 he lodged an appeal. On 2 April 2014 I.M.U. also lodged an appeal against the District Court\u2019s judgment. Despite requests from the applicant to expedite the proceedings in order to allow him to re-establish contact with his son, the case file could not be sent to the Prahova County Court before 7 May 2014 owing to administrative problems within the District Court.<\/p>\n<p>15.\u00a0\u00a0The start of the proceedings before the Prahova County Court was postponed on several occasions in order to allow the parties to get acquainted with the submissions in the file, to hear evidence and to obtain an expert evaluation of the relations between the parents and between each parent and the child. The County Court delivered its ruling on 22\u00a0October\u00a02015. It upheld the previous decision adopted by the District Court.<\/p>\n<p>16.\u00a0\u00a0Both parties lodged appeals against the County Court\u2019s decision. At the applicant\u2019s request, the case was sent to the Bucharest Court of Appeal. After several postponementsto the proceedings, on 2 November 2016 the Bucharest Court of Appeal delivered the final decision in the case. It upheld the ruling of the District Court, but made some amendments to the applicant\u2019s visiting schedule.<\/p>\n<p>17.\u00a0\u00a0On 19 February 2018 the child moved in with the applicant, at the boy\u2019s own express request and in accordance withan agreement signed before a notary by both parents, following the mother\u2019s decision to move permanently to another town.<\/p>\n<p>II.\u00a0\u00a0RELEVANT DOMESTIC LAW<\/p>\n<p>18.\u00a0\u00a0Article 6132of the Code of Civil Procedure (\u201cthe former Code\u201d), as applicable at the relevant time, provided that during divorce proceedings a court could order temporary measures by means of an interim injunction, concerning: custody of children, alimony, child allowance and use of the family home.The same provision was incorporated into Article 920 of the new Code of Civil Procedure, which entered into force on 15\u00a0February\u00a02013and is presently applicable.<\/p>\n<p><strong>THE LAW<\/strong><\/p>\n<p>I.\u00a0\u00a0ALLEGED VIOLATION OF ARTICLE 8 OF THE CONVENTION<\/p>\n<p>19.\u00a0\u00a0The applicant complained under Articles 6, 8, 14 and 17 of the Convention of the denial of his visiting rights by the courts and of the repercussions of the courts\u2019 decisions on his relationship with his son and on the child\u2019s psychological development. He further complained under Article\u00a08 that the divorce proceedings had lasted too long, thus endangering even further his relationship with his son.<\/p>\n<p>20.\u00a0\u00a0The Court, master of the characterisation to be given in law to the facts of the case (see Radomilja and Others v.Croatia [GC], nos.\u00a0<a href=\"https:\/\/laweuro.com\/?p=8645\">37685\/10 and 22768\/12<\/a>, \u00a7 114, 20 March 2018), will examine the complaint from the standpoint of Article 8 alone (see, for example and mutatis mutandis,Cristescu v.Romania, no. 13589\/07, \u00a7 50, 10 January 2012, and Jovanovic v.\u00a0Sweden, no. 10592\/12, \u00a7 53, 22 October 2015). Article 8 reads as follows:<\/p>\n<p>\u201c1.\u00a0\u00a0Everyone has the right to respect for his private and family life, his home and his correspondence.<\/p>\n<p>2.\u00a0\u00a0There shall be no interference by a public authority with the exercise of this right except such as is in accordance with the law and is necessary in a democratic society in the interests of national security, public safety or the economic well-being of the country, for the prevention of disorder or crime, for the protection of health or morals, or for the protection of the rights and freedoms of others.\u201d<\/p>\n<p><strong>A.\u00a0\u00a0Admissibility<\/strong><\/p>\n<p>21.\u00a0\u00a0The Court notes that the application is not manifestly ill-founded within the meaning of Article 35 \u00a7 3 (a) of the Convention. It furthermore notes that it is not inadmissible on any other grounds. It must therefore be declared admissible.<\/p>\n<p><strong>B.\u00a0\u00a0Merits<\/strong><\/p>\n<p><em>1.\u00a0\u00a0The parties\u2019 observations<\/em><\/p>\n<p>(a)\u00a0\u00a0The applicant<\/p>\n<p>22.\u00a0\u00a0The applicant complained that the courts had abusively refused his request for the establishment of visiting rights during the divorce proceedings, thus leaving the extent of his relationship with his son entirely at his spouse\u2019s discretion. He noted that the proceedings in respect of the interim injunction had lasted for more than seven months (from 2\u00a0November\u00a02012 until 27 May 2013 \u2013 see paragraphs 7 and 9 above) and that therefore, although he could have lodgedanother application for an interim injunction, that course of action would not have brought a swift resolution and could not have guaranteed a favourable outcome.<\/p>\n<p>23.\u00a0\u00a0He further pointed out that he had done everything to alert the domestic courts in respect of the necessity to expedite the divorce proceedings and argued that he had not been responsible for any delay in those proceedings.<\/p>\n<p>(b)\u00a0\u00a0The Government<\/p>\n<p>24.\u00a0\u00a0The Government contended that the applicant had never been prevented from visiting his child and that imposing a visiting schedule by means of a court order would have only exacerbated the deterioration of relations between the parents. They asserted that the lack of legislative provisions for awarding provisional visiting rights pending the outcome of divorce proceedings had not constituted the domestic courts\u2019 fundamental argument in dismissing his application.<\/p>\n<p>25.\u00a0\u00a0They furthermore pointed out that in similar situations the domestic courts consistently awarded visiting rights by means of an interim injunction if the best interests of the children concerned dictated it. They cited several examples of domestic case-law to this effect.<\/p>\n<p>26.\u00a0\u00a0The Government pointed out that if the applicant had been prevented from seeing his child, he could at any point have lodged a fresh application for an interim injunction, which would have been examined by the courts.<\/p>\n<p>27.\u00a0\u00a0Lastly, the Government contended that the authorities had not been responsible for the delays in the divorce proceedings and argued that the length of those proceedings had been reasonable and had not interfered with the applicant\u2019s right to family life.<\/p>\n<p><em>2.\u00a0\u00a0The Court\u2019s assessment<\/em><\/p>\n<p>28.\u00a0\u00a0The Court refers to the principles established in its case-law regarding the right to respect for family life (see, as a recent example, Mitrova and Savikv. the former Yugoslav Republic of Macedonia, no.\u00a042534\/09, \u00a7\u00a7 77-79, 11 February 2016).<\/p>\n<p>29.\u00a0\u00a0Turning to the facts of the present case, the Court notes that the domestic courts clearly stated that the law did not provide for granting visiting rights during divorce proceedings (see paragraphs 8, 9 and 18 above). The applicant\u2019s complaint relates to the effects that the application of this law had on his relationship with his son (see paragraph 11 above). It appears that after the decision of 8 January 2013 was taken, it became more difficult for the applicant to maintain contact with his son (see paragraphs\u00a010 and 11 above).<\/p>\n<p>30.\u00a0\u00a0The Court acknowledges that the domestic courts do not always reject as inadmissible such requests for visiting rights made during divorce proceedings (see paragraph 25 above). However, the applicant could not have benefited in any manner from the existence of more favourable domestic case-law, as decisions adopted by the domestic courts in individual cases are not binding on any other domestic courts and do not constitute as such a primary source of law.<\/p>\n<p>31.\u00a0\u00a0Moreover, the applicant could not have been expected to lodge a fresh application for an interim injunction, as indicated by the Government (see paragraph 26 above), as nothing in the law itself allowed him to expect a different outcome from the courts. When examining his request, the domestic courts did no more than apply the law, albeit in a restrictive manner. The Court considers that the provision of the law in question, by its very nature, removed the factual circumstances of the case from the scope of the domestic courts\u2019 examination (see, mutatis mutandis, X and Others v.\u00a0Austria [GC], no.19010\/07, \u00a7126, ECHR 2013).<\/p>\n<p>32.\u00a0\u00a0The Government argued that the absence of regulation had not been the fundamental reason given by the courts for dismissing the applicant\u2019s application for an interim injunction (see paragraph 24in fineabove). Be that as it may, the Court notes that that argument was prevalent in the domestic courts\u2019 decisions. Moreover, even the remaining argument \u2013 namely that the applicant was not prevented from seeing his child (see paragraph\u00a08 above) \u2013 cannot be construed as constituting an effective examination of the child\u2019s best interests, but rather as a mere observation of the situation at that particular moment. The domestic courts did not examine the precariousness of the situation, nor did they respond to the applicant\u2019s request for a more structured visiting plan (see paragraph 7 above). In other words, they left the exercise of a right which was fundamental to both the applicant and his child at the discretion of the applicant\u2019s spouse with whom he had (at that time) a conflictof interest (see paragraph 6 above).<\/p>\n<p>33.\u00a0\u00a0The Court notes that the hindrance complained of is by its very nature temporary, as it could only last as long as the divorce proceedings were pending. However, in the case at hand these proceedings, initiated on 13\u00a0September\u00a02012 (see paragraph 6 above), lasted for more than four\u00a0years (see paragraph 16 above). The applicant \u2013 and equally important, his child \u2013 wastherefore affected for about three years and five months \u2013 that is to say from 9 June 2013 (when he last saw his son \u2013 see paragraph 11 above) until 2\u00a0November\u00a02016 (when the divorce court gave the final rulingin the case \u2013 see paragraph 16 above). The Court considers that in the present case, the lengthiness of this period of timeleads it to find that the respondent State has failed to discharge its positive obligations under Article 8 of the Convention (see, for example, M. and M. v. Croatia, no.10161\/13, \u00a7\u00a7\u00a0179 and 182, ECHR 2015 (extracts), and Eberhard and M. v.\u00a0Slovenia, no.\u00a08673\/05 and 9733\/05, \u00a7\u00a7127 and 138-142, 1 December 2009).<\/p>\n<p>34.\u00a0\u00a0The foregoing considerations are sufficient to enable the Court to conclude that as regards the granting of visiting rights during divorce proceedings the Romanian authorities failed to meet their positive obligations arising from Article 8 of the Convention.The underlying problem lies with an insufficient quality of the domestic law.<\/p>\n<p>There has accordingly been a violation of this provision.<\/p>\n<p>35.\u00a0\u00a0In the light of the above conclusion, the Court considers that there is no need to make a separate ruling on the complaint concerning the length of the divorce proceedings.<\/p>\n<p>II.\u00a0\u00a0APPLICATION OF ARTICLE 41 OF THE CONVENTION<\/p>\n<p>36.\u00a0\u00a0Article 41 of the Convention provides:<\/p>\n<p>\u201cIf the Court finds that there has been a violation of the Convention or the Protocols thereto, and if the internal law of the High Contracting Party concerned allows only partial reparation to be made, the Court shall, if necessary, afford just satisfaction to the injured party.\u201d<\/p>\n<p><strong>A.\u00a0\u00a0Damage<\/strong><\/p>\n<p>37.\u00a0\u00a0The applicant claimed EUR 150,000 in respect of non-pecuniary damage for his and his son\u2019s suffering because of the separation imposed on them by I.M.U. as a consequence of the 8 January 2013 judgment. He furthermore claimed EUR 100,000 for the psychological and physical effort he had had to make in order to overcome the obstacles placed by the school administration(see paragraph 10 above) to his maintaining contact with his son.<\/p>\n<p>38.\u00a0\u00a0The Government opposed any award being made to the applicant\u2019s son, who was not a party to the instant proceedings. They furthermore argued that the finding of a violation constituted sufficient just satisfaction for the applicant. Lastly, they asserted that the amounts requested by the applicant were exorbitant and unjustified vis-\u00e0-vis the awards made by the Court in similar cases.<\/p>\n<p>39.\u00a0\u00a0Having regard to all the circumstances of the present case, the Court accepts that the applicant must have suffered non-pecuniary damage which cannot be compensated for solely by the finding of a violation. Making its assessment on an equitable basis, the Court awards the applicant EUR\u00a08,000 in respect of non-pecuniary damage, plus any tax that may be chargeable thereon. Lastly, bearing in mind that the applicant\u2019s son is not party to the present proceedings, the Court makes no award of damages to the child.<\/p>\n<p><strong>B.\u00a0\u00a0Costs and expenses<\/strong><\/p>\n<p>40.\u00a0\u00a0The applicant also claimed the following amounts for the costs incurred before the domestic courts and for those incurred before the Court:<\/p>\n<p>(a)\u00a0\u00a0RON 1,000 or EUR 230, representing costs charged to the applicant under the decision of 27 May 2013 (see paragraph 9 above);<\/p>\n<p>(b)\u00a0\u00a0RON 1,500 or EUR 350, representing costs for translating documents for the Court proceedings;<\/p>\n<p>(c)\u00a0\u00a0RON 8,000 or EUR 1,800, representing lawyer\u2019s fee in the Court proceedings.<\/p>\n<p>He produced receipts for these costs.<\/p>\n<p>41.\u00a0\u00a0The Government considered that the applicant\u2019s obligation to pay RON\u00a01,000 to I.M.U. was a logical consequence of his application for an interim injunction being dismissed as ill-founded by the domestic courts. They furthermore denied the applicant\u2019s right to reimbursement for the translation costs, and argued that he could have asked the Court\u2019s permission to use the Romanian language if he had not mastered sufficiently the official languages. For that reason, they considered this cost to have beenunjustified in respect of the proceedings. Lastly, they contended that the lawyer\u2019s fee was excessive and unjustified and also argued that a simple receipt, unaccompanied by a signed contract for assistance, was not sufficient to allow for the evaluation of the actual work performed by the lawyer.<\/p>\n<p>42.\u00a0\u00a0Regard being had to the documents in its possession and to its<br \/>\ncase-law, the Court considers it reasonable to award the total amount requested by the applicant \u2013 that is to say EUR 2,380, covering costs under all heads.<\/p>\n<p><strong>C.\u00a0\u00a0Default interest<\/strong><\/p>\n<p>43.\u00a0\u00a0The Court considers it appropriate that the default interest rate should be based on the marginal lending rate of the European Central Bank, to which should be added three percentage points.<\/p>\n<p><strong>FOR THESE REASONS, THE COURT, UNANIMOUSLY,<\/strong><\/p>\n<p>1.\u00a0\u00a0Declaresthe application admissible;<\/p>\n<p>2.\u00a0\u00a0Holdsthat there has been a violation of Article 8 of the Convention in respect of the impossibility of granting of visiting rights during divorce proceedings;<\/p>\n<p>3.\u00a0\u00a0Holds that there is no need to examine separately whether there has been a violation of Article 8 of the Convention also on account of the length of the divorce proceedings;<\/p>\n<p>4.\u00a0\u00a0Holds<\/p>\n<p>(a)\u00a0\u00a0that the respondent State is to pay the applicant, within three\u00a0months from the date on which the judgment becomes final, in accordance with Article\u00a044\u00a0\u00a7\u00a02 of the Convention, the following amounts, to be converted into the currency of the respondent State at the rate applicable at the date of settlement:<\/p>\n<p>(i)\u00a0\u00a0EUR 8,000 (eight thousand euros), plus any tax that may be chargeable, in respect of non-pecuniary damage;<\/p>\n<p>(ii)\u00a0\u00a0EUR 2,380 (two thousand three hundred and eighty euros), plus any tax that may be chargeable to the applicant, in respect of costs and expenses;<\/p>\n<p>(b)\u00a0\u00a0that from the expiry of the above-mentioned three months until settlement simple interest shall be payable on the above amounts at a rate equal to the marginal lending rate of the European Central Bank during the default period, plus three percentage points;<\/p>\n<p>5.\u00a0\u00a0Dismissesthe remainder of the applicant\u2019s claim for just satisfaction.<\/p>\n<p>Done in English, and notified in writing on 4 September 2018, pursuant to Rule77\u00a7\u00a72 and 3 of the Rules of Court.<\/p>\n<p>Marialena Tsirli\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Ganna Yudkivska<br \/>\nRegistrar\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 President<\/p>\n<div class=\"social-share-buttons\"><a href=\"https:\/\/www.facebook.com\/sharer\/sharer.php?u=https:\/\/laweuro.com\/?p=5702\" target=\"_blank\" rel=\"noopener\">Facebook<\/a><a href=\"https:\/\/twitter.com\/intent\/tweet?url=https:\/\/laweuro.com\/?p=5702&text=CASE+OF+CRISTIAN+CATALIN+UNGUREANU+v.+ROMANIA+%28European+Court+of+Human+Rights%29\" target=\"_blank\" rel=\"noopener\">Twitter<\/a><a href=\"https:\/\/www.linkedin.com\/shareArticle?url=https:\/\/laweuro.com\/?p=5702&title=CASE+OF+CRISTIAN+CATALIN+UNGUREANU+v.+ROMANIA+%28European+Court+of+Human+Rights%29\" target=\"_blank\" rel=\"noopener\">LinkedIn<\/a><a href=\"https:\/\/pinterest.com\/pin\/create\/button\/?url=https:\/\/laweuro.com\/?p=5702&description=CASE+OF+CRISTIAN+CATALIN+UNGUREANU+v.+ROMANIA+%28European+Court+of+Human+Rights%29\" target=\"_blank\" rel=\"noopener\">Pinterest<\/a><\/div>","protected":false},"excerpt":{"rendered":"<p>FOURTH SECTION CASE OF CRISTIAN C\u0102T\u0102LIN UNGUREANU v. ROMANIA (Application no. 6221\/14) JUDGMENT STRASBOURG 4 September 2018 FINAL 04\/12\/2018 This judgment has become final under Article 44 \u00a7 2 of the Convention. It may be subject to editorial revision. In&hellip;<\/p>\n<p class=\"more-link-p\"><a class=\"more-link\" href=\"https:\/\/laweuro.com\/?p=5702\">Read more &rarr;<\/a><\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[1],"tags":[],"class_list":["post-5702","post","type-post","status-publish","format-standard","hentry","category-available-in-english"],"_links":{"self":[{"href":"https:\/\/laweuro.com\/index.php?rest_route=\/wp\/v2\/posts\/5702","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/laweuro.com\/index.php?rest_route=\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/laweuro.com\/index.php?rest_route=\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/laweuro.com\/index.php?rest_route=\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/laweuro.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcomments&post=5702"}],"version-history":[{"count":3,"href":"https:\/\/laweuro.com\/index.php?rest_route=\/wp\/v2\/posts\/5702\/revisions"}],"predecessor-version":[{"id":12597,"href":"https:\/\/laweuro.com\/index.php?rest_route=\/wp\/v2\/posts\/5702\/revisions\/12597"}],"wp:attachment":[{"href":"https:\/\/laweuro.com\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=5702"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/laweuro.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcategories&post=5702"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/laweuro.com\/index.php?rest_route=%2Fwp%2Fv2%2Ftags&post=5702"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}