32 Legal Digest of International Fair Trial Rights use of public land;83 the nationalization and restitution of private property;84 or licensing for commercial activities.85 (c) Other procedures that, depending on the particular rights and obligations in question, might also be assessed on a case-by-case basis as involving a determination of rights and obligations in a suit at law.86 In this third category, child custody and other family proceedings have been treated as falling within the meaning of a “suit at law” or “civil” proceeding.87 Cutting across all categories, the European Court of Human Rights has found that for a right to be a “civil” one, it is sufficient that the subject matter of the action is itself of a pecuniary nature. This does not mean that proceedings are “civil” merely because they have economic implications. The action must itself be “pecuniary” in nature and founded on an alleged infringement of rights which are likewise pecuniary rights.88 In other words, the outcome of the proceedings should be directly decisive for the pecuniary rights at stake. The right to compensation following the acquittal of a person who had been held in detention was, therefore, found to involve civil proceedings under Article 6(1) of the EHCR, as was the right to compensation for continued detention following the discontinuation of proceedings.89 The interpretation of the European Court of Human Rights of the concept of civil rights and obligations has evolved and become more and more liberal, particularly in cases involving elements of public law. Two areas where the European Court has strikingly modified its initial viewpoints concern: a) disputes over civil service employment; and b) entitlements deriving from social security. a) Disputes over civil service employment Until 1999, disputes concerning civil service employment had followed the general rule that Article 6(1) of the ECHR did not apply where pecuniary claims were not central but only accessory to the main claim regarding, for instance, access to or dismissal from the civil service.90 In Pellegrin v France, the European Court of Human Rights adopted a functional 83 Äärelä and Näkkäläjärvi v Finland, HRC Communication 779/1997, UN Doc CCPR/C/73/D/779/1997 (2001), paras 7.2–7.4. 84 Krcmar and Others v the Czech Republic [2000] ECHR 99. 85 König v Germany [1978] ECHR 3. 86 UN Human Rights Committee, CCPR General Comment 32 (2007), para 16. 87 See, for example: Fei v Colombia, HRC Communication 514/1992, UN Doc CCPR/C/53/D/514/1992 (1995); Airey v Ireland [1979] ECHR 3 (family law); Olsson v Sweden (No 1) [1988] ECHR 2 (child care); Eriksson v Sweden [1989] ECHR 10 (fostering); and Keegan v Ireland [1994] ECHR 18 (adoption). 88 Editions Périscope v France [1992] ECHR 43, para 40; and Werner v Austria [1997] ECHR 92, para 38; S. a. r. l. du Parc d’Activites de Blotzheim and SCI Haselaecker v France [2003] ECHR, para 9; Procola v Luxembourg [1995] ECHR 33, para 38. 89 Georgiadis v Greece [1997] ECHR 28, para 35; and Werner v Austria [1997] ECHR 92, para 39. 90 Nicodemo v Italy [1997] ECHR 62, para 18; De Santa v Italy [1997] ECHR 56, para 18; Lapalorcia v Italy [1997] ECHR 61, para 21.