Kernrechtsfrage
Whether the disciplinary proceedings were a criminal charge for purposes of Article 6 ECHR.
Extrahierter Entscheid
No. The lawyer disciplinary regime was administrative in nature and the CHF 5,000 disciplinary payment was not a criminal penalty.
Extrahierte Begründung
The court held that the purpose of the rules is protection of the public and the administration of justice, not retribution. The sanction was expressly a 'disciplinary measure' under cantonal law, directed only at lawyers, and was not severe enough to trigger Article 6 by its weight alone.