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SAUNDERS v. UNITED KINGDOM JUDGMENT
DISSENTING OPINION OF JUDGE MARTENS, JOINED BY JUDGE KURIS
Murray judgment, namely its reliance on generally recognised international
standards7, does certainly not justify this decision: both under the Fifth
Amendment to the United States Constitution8 and under the case-law of the
Court of Justice of the European Communities9 there is a right to remain
silent, but in principle not a right to refuse to hand over documents, let alone
an absolute right to do so.
12. It is, however, at least open to doubt whether the Court in paragraph
69 of its present judgment has not - implicitly, without saying so openly, let
alone without adducing cogent reasons for doing so - overruled Funke and
essentially converted to the more restricted doctrine adopted inter alia by the
Court of Justice of the European Communities. In this context it is
significant that paragraph 69 refers to how the privilege against selfincrimination is understood "in the legal systems of the Contracting States
and elsewhere". What is more important is that, whilst the first sentence of
paragraph 69 seems to amalgamate the privilege against self-incrimination
with the right to remain silent, the second sentence seems to imply that contrary to Funke - the privilege does not comprise the power to refuse to
hand over incriminating documents nor that to prevent the use of such
documents, obtained under compulsion, in criminal proceedings.
I confess that I fail to see any other possible construction of paragraph 69
so that I presume that the above interpretation is correct. On that assumption
two points should be made.
The first is that the merging of the conceptually broader right not to
incriminate oneself with the right to remain silent reduces the scope of
protection afforded to suspects. In my understanding of the privilege against
7
See paragraph 5 above.
There is only a valid Fifth Amendment claim if, due to the particular facts and
circumstances of the case, the "act of producing" is both "testimonial" and "incriminating".
To be noted: when a custodian of a collective entity produces the corporate records and
documents his act does not constitute testimonial self-incrimination; he is, however,
protected from condemning himself by his own oral testimony. In the context of my dissent
in the present case it is of interest to note one of the Supreme Court's arguments for this
restrictive doctrine:
"We note further that recognising a Fifth Amendment privilege on behalf of the records
custodians of collective entities would have a detrimental impact on the Government's
efforts to prosecute `white-collar crime', one of the most serious problems confronting the
law-enforcement authorities. `The greater portion of evidence in wrongdoing by an
organisation or its representatives is usually found in the official records and documents of
that organisation. Were the cloak of the privilege to be thrown around these impersonal
records and documents, effective enforcement of many federal and State laws would be
impossible.' ... If custodians could assert a privilege, authorities would be stymied not only
in their enforcement efforts against those individuals but also in their prosecutions of
organisations." (Braswell v. US 487 US 99 (1988)).
9
See its Orkem/Commission judgment of 18 October 1989 (374/87 [1989] ECR I-3343 et
seq.) and its Otto/Postbank judgment of 10 November 1993 (C-60/92 [1993] ECR I-5683 et
seq.).
8
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