Question juridique clé
Whether a CHF 200 fine could be imposed under Art. 20a SchKG for a manifestly unfounded supervisory complaint.
Solution extraite
Yes. A fine is permissible where the complaint is vexatious or in bad faith; the cantonal authority did not violate federal law.
Motifs extraits
Art. 20a(1) SchKG allows fines only for vexatious or bad-faith complaints, not merely for discourteous behavior. The authority based the fine on the obvious baselessness of the recusal request, and the amount was proportionate in light of the circumstances and the appellant's financial situation.