Kernrechtsfrage
Whether the three-year suspension of the permit under Art. 22b para. 1 VOCV was proportionate in this case
Extrahierter Entscheid
Although Art. 22b para. 1 VOCV is generally compatible with proportionality, the specific late filing here was a minor breach and the sanction was disproportionate in the individual case.
Extrahierte Begründung
The delay was only about two weeks, prior years were filed on time, the 2008 filing was timely again, the balance was substantively plausible, and the procedure also depended on a prior administrative review.