Question juridique clé
Whether a fax submission can preserve the criminal appeal deadline under Art. 91 StPO
Solution extraite
No. A fax does not satisfy the filing requirements for written submissions; the deadline is met only by delivery to the competent authority or specified channels within the statutory time.
Motifs extraits
Art. 91 StPO mirrors Art. 48 BGG on deadline preservation. Consistent Federal Supreme Court case law holds that fax transmission does not suffice for pleadings requiring written form, and prior cantonal practice cannot override this interpretation.