Question juridique clé
Whether the cantonal bar chamber had to be recused for structural bias under Article 6(1) ECHR and Article 30(1) of the Federal Constitution.
Solution extraite
No. The chamber could decide as first-instance authority because its decisions were subject to judicial review by the cantonal administrative court with full cognition in fact and law; Article 6(1) ECHR does not require review of expediency.
Motifs extraits
Article 6(1) ECHR is satisfied if an administrative authority is followed by an independent and impartial court with unrestricted review of decisive facts and law. A power to review expediency is not required, and the absence of such review under cantonal law did not create a violation here.