132 Legal Digest of International Fair Trial Rights In the context of the establishment of parenthood, child custody proceedings, or proceedings concerning access of a divorced parent to her/his children, and in general in cases involving civil status and capacity, the Human Rights Committee and European Court of Human Rights have similarly required that such issues be adjudicated expeditiously.567 In H. v the United Kingdom, the European Court stated that, in cases of this kind, in view of what is at stake for the applicant: “the authorities are under a duty to exercise exceptional diligence since there is always the danger that any procedural delay will result in the de facto determination of the issue submitted to the court before it has held its hearing.” 568 In Jevremovic v Serbia, for example, and notwithstanding the complexity of the case, a period of four years and nine months was found to be in violation of Article 6(1) of the ECHR in proceedings for the establishment of paternity and child custody.569 In contrast, in Hokkanen v Finland, a similar case concerning child custody, a period of 18 months comprising three judicial levels was found by the European Court to be reasonable.570 The need for civil hearings to proceed in an expeditious way has also been found in cases where the health of one of the parties was at issue (in a claim by an applicant who had contracted HIV from an infected blood transfusion),571 employment disputes572 and personal injury cases where an applicant has suffered serious personal injury.573 Where delays in civil proceedings are caused by a lack of resources or under-funding, the Committee has commented that, to the extent possible, supplementary budgetary resources should be allocated for the administration of justice.574 Notably, and in combination with the right to effective remedies under Article 2(3) of the Covenant, excessive delays on the part of administrative authorities in implementing judicial decisions has been treated as a violation of Article 14(1).575 567 Tcholatch v Canada, HRC Communication 1052/2002, UN Doc CCPR/C/89/D/1052/2002 (2007), paras 8.9–8.11; E. B. v New Zealand, HRC Communication 1368/2007, UN Doc CCPR/C/89/D/1368/2005 (2007), paras 9.2–9.4; and Hokkanen v Finland [1994] ECHR 32, para 72. 568 H. v the United Kingdom [1987] ECHR 14, para 85. See also Bock v Germany [1989] ECHR 3, para 49. 569 Jevremovic v Serbia [2007] ECHR 612, para 86. 570 Hokkanen v Finland [1994] ECHR 32, para 72. 571 X v France [1992] ECHR 45, especially paras 47–49. 572 Obermeier v Austria [1990] ECHR 15, para 72; Frydlender v France [2000] ECHR 353, para 45. 573 Silva Pontes v Portugal [1994] ECHR 12, para 39. 574 UN Human Rights Committee, CCPR General Comment 32 (2007), para 27. 575 Czernin v the Czech Republic, HRC Communication 823/1998, UN Doc CCPR/C/83/D/823/1998 (2005), para 7.5.