Information Note on the Court’s case-law No. 90
October 2006
Kök v. Turkey - 1855/02
Judgment 19.10.2006 [Section III]
Article 6
Civil proceedings
Article 6-1
Civil rights and obligations
Dispute over the right to continue specialist medical training begun in a different country: article 6 applicable
Article 2 of Protocol No. 1
Right to education
Refusal to recognise specialist medical training undertaken abroad for failure to satisfy the relevant criteria: no violation
Facts: The applicant had completed her general medical studies and part of her specialist training in Bulgaria. In Turkey, her university medical degree was recognised as equivalent and she worked in that country as a doctor; however, the length of the period of specialist training she had undergone in Bulgaria was not recognised, as it did not satisfy the requirements.
Law: Article 6(1) Applicability – The applicant had been claiming the right to continue the medical specialisation she had begun outside the country in order to practise as a specialist in Turkey. She had further sought the setting-aside of the authorities’ decision refusing her request for recognition. Article 6(1) was applicable.
Article 2 of Protocol No. 1 – The refusal of the authorities to recognise the length of the period of specialist training which the applicant had undergone in Bulgaria did not amount in the instant case to a restriction of her right to education.
Conclusion: no violation (unanimously).
For further details see Press Release no. 615.
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This summary by the Registry does not bind the Court.
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