Article 3 of the European Convention on Human Rights: A Practitioner’s Handbook Cases before a Committee are communicated to the respondent Government if the case is not declared inadmissible. Since Committee cases are repetitive cases to which well established case law exists, the Court does not expect the Government to reply.102 2.1.11 Legal Representation Upon communication of the application to the respondent Government, the applicant must be represented by a lawyer.103 The application form may be completed and submitted to the Court by the applicant him- or herself, but after the communication of the application to the respondent Government, representation by a lawyer is mandatory. Consequently, in Grimaylo v. Ukraine,104 the Court struck out the application from its list of cases because of the applicant’s refusal to appoint a lawyer to represent him. Although Mr. Grimaylo insisted on representing himself or appointing his wife to represent him, the Court was of the opinion that a lawyer’s participation was essential, given the complexity of the case from a legal and factual point of view. There are two exceptions to the requirement of legal representation. First, the President of the Chamber may exceptionally grant leave from this obligation.105 In the case of Portmann v. Switzerland,106 the applicant was exempted from the obligation to be represented by a lawyer since he was unable to find a lawyer who would take his case. Second, if an application is subject to well-established case law according to Article 28 of the Convention and therefore decided by a Committee, the Court’s practice is to grant leave from the requirement of legal representation.107 As a general rule, the representative should be an lawyer authorised to practise in any of the Contracting Parties and resident in the territory of one of them.108 The Court may also authorize other representatives, such as academic lawyers, who are not authorized to practice in a Convention State. In this case, specific authorisation by the Court needs to be sought. Although legal representation is not required at the time of lodging the application, it is strongly recommended for a number of reasons. The most important reason is the risk that a Single Judge or a Committee declares an application inadmissible 102 See Philip Leach, Taking a Case to the European Court of Human Rights. Oxford University Press, 2011, p. 43. 103 Rule 36 § 2 of the Rules of Court. 104 Grimaylo v. Ukraine (dec.), no. 69364/01, 7 February 2006. 105 Rule 36 § 4 of the Rules of Court. 106 Portmann v. Switzerland, no. 38455/06, 11 October 2011, § 5. 107 Philip Leach, Taking a Case to the European Court of Human Rights, Oxford University Press, 2011, p. 21. 108 Rule 36 § 4 of the Rules of Court. 54