Question juridique clé
Whether the appeal against the first-instance legal aid fee order was filed within the ten-day deadline
Solution extraite
The appeal was late because service was deemed completed seven days after failed registered delivery, and the later ordinary mailing did not restart the deadline.
Motifs extraits
Under summary proceedings for legal aid, the appeal period was ten days. Because the appellant had to expect service, the uncollected registered mailing was deemed notified on 12 March 2014. The period expired on 24 March 2014; the later A-mail re-sending on 19 March 2014 had no legal effect.