Question juridique clé
Whether the complainant had standing under Art. 81 LTF to file a criminal appeal against the refusal to admit him as civil party.
Solution extraite
He lacked standing because he was neither private prosecutor, LAVI victim, nor a complainant within Art. 81(1)(b) ch. 4-6 LTF, and he asserted only grievances on the merits.
Motifs extraits
The Court held that Art. 81 LTF does not extend standing to every injured person; a mere injured party has only a factual, not a legal, interest in prosecution. Procedural complaints are admissible only as formal denial-of-justice grievances, not to challenge the merits indirectly.