Published on 20 October 2025
FIFTH SECTION
Application no. 11333/25
Paride ANDREOLI
against San Marino
lodged on 3 April 2025
communicated on 1 October 2025
SUBJECT MATTER OF THE CASE
The application concerns the length of criminal proceedings. The applicant was informed of a criminal investigation against him, for inter alia money laundering, on 15 March 2016. Thereafter the applicant resigned from his parliamentary role. A bill of an indictment was issued on 27 April 2020 and by a first-instance judgment of 17 February 2025 the proceedings were discontinued, the charges having become time-barred.
The applicant complains under Article 6 about the length of the criminal proceedings.
QUESTIONS TO THE PARTIES
1. Has the applicant exhausted domestic remedies in the present case? In particular, given the limitations of the new remedy under Law no. 60 of 2025 as may apply in the present case (see, in particular, Article 2 (4) and Article 3 (5) of Law no. 60 of 2025 excluding the investigation period for the purposes of the calculation of the duration of proceedings, and excluding in principle damage in the case of proceedings which result in a discontinuation due to time-barring) can it be said that the applicant had an effective remedy which he should have pursued?
2. Was the length of the proceedings in the present case in breach of the “reasonable time” requirement of Article 6 § 1 of the Convention (compare Frydlender v. France [GC], no. 30979/96, § 43, ECHR 2000-VII, and Tierce v. San Marino, no. 69700/01, § 30, ECHR 2003‑VII)?