The European Court of Human Rights (Third Section), in the case Dyachenko and Others v. Ukraine – 6 July 2017, after considering that the complaints raised by the applicants in application no. 26417/08 concerning the proceedings between 27 March 1997 and 10 September 1997 were incompatible ratione temporis and thus must be rejected in accordance with Article 35 §§ 3 and 4 of the Convention, as the Convention entered into force with respect to Ukraine on 11 September 1997, found that in the instant case the length of the proceedings was excessive and failed to meet the “reasonable time” requirement and that the applicants did not have at their disposal an effective remedy in respect of these complaints.
The Court, referring to its previous case law (Frydlender v. France [GC] n. 30979/96, Svetlana Naumenko v. Ukraine no. 41984/98, 9 November 2004 and Efimenko v. Ukraine, no. 55870/00, 18 July 2006), reiterated that the reasonableness of the length of proceedings must be assessed in the light of the circumstances of the case and with reference to the following criteria: the complexity of the case, the conduct of the applicants and the relevant authorities and what was at stake for the applicants in the dispute.
