In addition, in many cases the former Commission and the Court have reviewed various aspects of permission-to-appeal or similar proceedings under that provision (see Webb v. the United Kingdom, no. 33186/96, Commission decision of 2 July 1997, unreported; ITC (Isle of Man), P.S.W.H. and A.G.S. v. the United Kingdom (dec.), no. 45619/99, 29 February 2000; Nerva and Others v. the United Kingdom (dec.), no. 42295/98, 11 July 2000; Sawoniuk v. the United Kingdom (dec.), no. 63716/00, ECHR 2001-VI; Walczak v. Poland (dec.), no. 77395/01, 7 May 2002; Stepinska v. France, no. 1814/02, §§ 15-19, 15 June 2004; Guz v. Poland (dec.), no. 29293/02, 19 May 2005; Martinie v. France [GC], no. 58675/00, §§ 53-55, ECHR 2006-VI; Stepenska v. Ukraine (dec.), no. 24079/02, 12 June 2006; Jaczkó v. Hungary, no. 40109/03, § 29, 18 July 2006; Marini v. Albania, no. 3738/02, § 106, 18 December 2007; Mrúz v. Hungary, no. 3261/05, § 20, 14 October 2008; Lajos Németh v. Hungary, no. 3840/05, § 20, 21 October 2008; Makuszewski v. Poland, no. 35556/05, § 53, 13 January 2009; Grori v. Albania, no. 25336/04, § 199, 7 July 2009; Wnuk v. Poland (dec.), no. 38308/05, 1 September 2009; Jakupi v. Albania (dec.), no. 11186/03, 1 December 2009; Nersesyan v. Armenia (dec.), no. 15371/07, §§ 23-25, 19 January 2010; Bachowski v. Poland (dec.), no. 32463/06, 2 November 2010; and Dunn v. the United Kingdom (dec.), no. 62793/10, §§ 27-40, 23 October 2012).

The Court has already held that a constitutional complaint is, in principle, an effective remedy and is thus required for exhaustion purposes in respect of an applicant's right to a fair hearing under Article 6 of the Convention (see, mutatis mutandis, Balliu v. Albania (dec.), no. 74727/01, 30 September 2004; Beshiri and Others v. Albania, no. 7352/03, §§ 30-34, 22 August 2006; Jakupi v. Albania (dec.), no. 11186/03, 1 December 2009; and for a similar conclusion, Muçaj v. Albania [Committee], no. 37814/10, § 26, 11 July 2023).