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With reference to the Court's judgment in the Airey v. Ireland case (Series A no. 32), the applicants further aver that the Court of Appeal's refusal to grant an adjournment of the hearing amounted to an infringement of their right of access to a court since, without the benefit of legal representation, they were faced with the task of dealing unassisted with a case which Lord Justice Phillips had described in the leave to appeal proceedings as involving "not only difficult questions of analysis of evidence but potentially difficult questions of law.".

However, despite the absence of a similar clause for civil litigation, Article 6 § 1 may sometimes compel the State to provide for the assistance of a lawyer when such assistance proves indispensable for effective access to a court either because legal representation is rendered compulsory, as is done by the domestic law of certain Contracting States for various types of litigation, or by reason of the complexity of the procedure in the case (see the Airey v. Ireland judgment of 9 October 1979, Series A no. 32, pp. 15-16, § 26 in fine).

Auszug aus EGMR, 28.09.1999 - 49167/99

Thus, although these provisions have a certain relevance outside the strict confines of criminal law, the Contracting States have greater latitude when dealing with civil cases concerning civil rights and obligations than they have when dealing with criminal cases (see the Dombo Beheer B.V. v. the Netherlands judgment of 27 October 1993, Series A no. 274, p. 19, § 32).