NGOs under European Convention on Human Rights / Tymofeyeva

applicant’s impossibility to complain against a state who has not ratified the Protocol to the Convention. 1267 The Netherlands still has not ratified Protocol No. 7, though the state has a long tradition of corporate criminal liability. 1268 On 1 August 2002 and 1 December 2008, respectively, Convention No. 173 1269 and Convention No. 198 1270 entered into force for this country. Nevertheless, the absence of obligations under Protocol No. 7 prevents the Court from delivering judgments concerning violations of the Articles of this Protocol. The situation would be the same for Article 34 NGOs from Germany, Turkey and the United Kingdom. The following part of the book will contemplate an alleged violation of Article 4 of Protocol No. 7 to the Convention regarding non-governmental organisations in the meaning of Article 34 of the Convention. This is the first Article in this Protocol where the Court ruled on breaches of Article 34 NGO’s rights.

1267 Practical Guide On Admissibility Criteria. Council of Europe/European Court of Human Rights, 2011, p. 35 with reference to the cases Horsham v. the United Kingdom (dec.); and De Saedeleer v. Belgium , § 68. 1268 Corporate Liability inEurope byCliffordChance LLP January 2012. URL: accessed 20 July 2015. 1269 Criminal Law Convention on Corruption, Strasbourg, cited above. 1270 Convention on Laundering, Search, Seizure and Confiscation of the Proceeds from Crime and on the Financing of Terrorism, cited above.

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