Whether a substitute custodial sentence had to be fixed for the 300 CHF fine imposed for voies de fait.
Yes. Under Art. 106 CP, when a fine is imposed the court must also set a substitute custodial sentence in case of culpable non-payment.
The first-instance court imposed a 300 CHF fine to sanction the minor assault but failed to specify the substitute sentence required by law. Considering the offender's financial situation, the court set the substitute term by converting the fine at the day-fine rate of 10 CHF.