Another situation, sporadic, but still recurrent, is the one in which citizens challenged the requirement of an address in order to obtain the citizen’s card. In a particular case, it was defended the sufficiency of the postal box. However, it was stressed that although the citizen’s card fulfills primarily a function of civil identification, its importance is transversal to several public entities, requiring particular caution in the collection and filling of its elements, with particular emphasis on the address which assumes a central role in the communication between the State and Public Administration services and the holder of the document. In this regard, the law regulating the issuance and use of a citizen’s card states that «the address is the physical postal address freely indicated by the citizen, corresponding to the place of residence where he can be regularly contacted»(35). Therefore, strictly speaking, the postal box does not correspond to the place of residence. In fact, having the purpose of the deposit of correspondence, the postal box does not integrate the concept of residence, commonly understood as the place that provides the basis for the life of a natural person, where it might be found. The Institute of Registers and Notaries (IRN) has informed that the address of a support institution is accepted whenever the holder of the identification document has not had a fixed residence and is being accompanied by that entity. Questions concerning the spelling of names were also the subject of many complaints, not only on the need for it to be in accordance with the birth registers, but also on the need to use the mechanism of Article 103 (1) of the Code of Civil Registry (IRN intervention through the Central Registry Office). In the scope of procedural investigation, this State body concluded that in this matter the action of the administration was not susceptible of censorship. With regard to the car Registry, questions are still being raised, although residually, on the requirement of payment of the Single Road Tax (IUC) in case of the absence of deregistration of the vehicle. Similarly the cost of registration acts was also contested. In the scope of a procedure in which the subject of the complaint was the increased cost of a registration act, it was not recognized the reason to the complainant, as such a rise in cost had a legal basis. However, in the course of the investigation, this State body verified that the services did not discriminate the amounts charged on the issued invoice. Following the intervention of the Ombudsman with the IRN, the administrative action was modified accordingly, in order to issue a detailed bill of the registration request, with receipt value, with all the notary fees charged broken down, specifying all the sums comprised, with reference to respective regulations and indication of the whole amount due(36). (35)  See article 13 (1) of the Law No. 7/2007, of February 5, in its current wording. (36)  See positions adopted 2016, pp. 171-172. | 57

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