European Court of Human Rights - case of Kangasluoma v. Finland (2004) (excerpts)

European Court of Human Rights - case of Kangasluoma v. Finland (2004) (excerpts)

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26.  The Court recalls that the period to be taken into account in the assessment of the length of the proceedings starts from an official notification given to an individual by the competent authority of an allegation that he has committed a criminal offence or some from other act which carries the implication of such an allegation and which likewise substantially affects the situation of the suspect (see Corigliano v. Italy, judgment of 10 December 1982, Series A no. A-57, § 34). According to the Court’s constant case-law, a person has been found to be subject to a “charge”, inter alia, when a preliminary investigation has been opened in his case and, although not under arrest, the applicant has officially learned of the investigation or has begun to be affected by it. In the present case the Court finds that the applicant officially learned of the investigation at the time when he was interrogated by police for the first time, in December 1990.