Sandor Atilla Rumpler v The Regional Court in Budapest, Hungary
[2024] EWHC 258 (Admin)
Janos Vidák v Regional Court of Budapest (Hungary)
10 May 2023
[2023] EWHC 1108 (Admin)
High Court
A man fled Hungary after being sentenced to prison for theft. He was caught in the UK and fought extradition. The judge decided that although his life in the UK would be affected, his crimes were serious enough that he must return to Hungary to serve his sentence. The time he spent under house arrest didn't reduce his sentence.
Key Facts
- •Janos Vidák is sought by Hungary for nine theft and property damage offenses committed in 2010, resulting in losses exceeding £18,000.
- •He was sentenced to two years' imprisonment in 2014, but fled to the UK before serving the sentence.
- •He was arrested in the UK in 2019 and has been on remand and then electronic curfew since then.
- •The extradition hearing in the UK focused on Article 8 ECHR (right to private and family life).
- •The main question is whether the time spent on curfew in the UK should count towards his sentence and if he is eligible for early release in Hungary.
Legal Principles
Article 8 ECHR (right to private and family life) in the context of extradition.
European Convention on Human Rights
Proportionality test under Article 8 ECHR. Balancing the public interest in extradition against the individual's right to private and family life.
Case law: Norris v USA, HH v Italy, Celinski v Poland
Framework Decision 2002/584: Deduction of detention periods from sentences. Only periods of actual deprivation of liberty are deductible.
Case C-294/16 PPU JZ v Prokuratura Rejonowa Łódź – Śródmieście
Appellate court intervention in extradition decisions is limited.
Love v USA
Outcomes
Appeal dismissed; extradition ordered.
The court found that the public interest in extradition outweighed Vidák's Article 8 rights. The seriousness of the offenses, his fugitive status, and the Hungarian court's judgment were key factors. Time spent on curfew was not deemed deductible from his sentence, and the possibility of early release remained uncertain.
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