Question juridique clé
Whether the appellant had standing under Art. 88 OJ to challenge the criminal dismissal order
Solution extraite
He lacked standing because he sought protection of a merely factual or indirect interest in prosecution, not a legally protected personal interest.
Motifs extraits
In dismissal or non-prosecution cases, a complainant generally cannot rely on Art. 88 OJ; standing exists only exceptionally for victims under the Victims Assistance Act, which did not apply.