Question juridique clé
Whether the conditions for mandatory ex officio defense under Art. 36(1) PPF were still met after release from detention.
Solution extraite
No. The complainant was not shown to be manifestly incapable of defending himself, and the case did not present exceptional circumstances requiring mandatory defense at the investigation stage.
Motifs extraits
Art. 36(1) PPF must be interpreted restrictively in light of constitutional and ECHR guarantees; mere complexity of the case is insufficient, and no concrete circumstance made self-defense impossible.