Fennell, Letts and Wilson, Mental Health Tribunals (Law Society 2013):
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Varbanov v Bulgaria 31365/96 (2000) ECHR 457

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(1) Violation of Article 5(1): Deprivation of liberty was not justified under Art 5(1)(e) and had no basis in domestic law which, moreover, did not provide the required protection against arbitrariness as it did not require the seeking of a medical opinion. (2) Violation Article 5(3): The applicant could only appeal to prosecutors and so was deprived of his right to have the lawfulness of his detention reviewed by a court.

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