Kernrechtsfrage
Whether the complainant had standing to appeal the refusal to order telephone-record evidence.
Extrahierter Entscheid
No standing existed because the alleged offence of obstructing justice protects a collective interest, not a direct individual legal interest of the complainant.
Extrahierte Begründung
A complainant may appeal only if the challenged decision can affect civil claims and the person is directly injured by the offence. Obstructing justice under Art. 305 CP primarily protects the proper administration of justice, which is a collective interest; indirect impact on private interests is insufficient.