Key legal question
Whether the Tribunal administratif wrongly found the first withdrawal appeal time-barred because notice by publication was invalid.
Extracted holding
The publication service was valid because the authority had no known current address for the driver and, under cantonal procedure, publication was permitted; Article 23(1) LCR was not breached.
Extracted reasoning
The authority had unsuccessfully tried to serve the decision at the address appearing in the records and on the licence. The driver had failed to inform the authority of his change of domicile, and the cantonal publication mechanism satisfied the federal requirement of written notice with reasons.