Both the former Commission and the Court have examined the applicability of the civil limb of Article 6 in the context of fines imposed on the parties to legal proceedings for abuse of process or contempt of court, and found that such fines aim to ensure the proper administration of justice and therefore have the characteristics of procedural sanctions that do not involve the determination of civil rights or obligations (see, for example, Veriter v. France, no. 25308/94, Commission decision of 2 September 1996, Decisions and Reports 86-B, p. 101; Schreiber and Boetsch v. France (dec.), no. 58751/00, ECHR 2003-XII; and Zugic v. Croatia, no. 3699/08, § 63, 31 May 2011).

The Court reiterates that the question whether the criminal head of Article 6 applies to contempt of court proceedings has to be assessed in the light of the three alternative criteria laid down by the Court in the Engel case (see Engel and Others v. the Netherlands, 8 June 1976, § 82, Series A no. 22): (a) the classification of the offence under the domestic law, (b) the nature of the offence and (c) the nature and degree of severity of the penalty that the person concerned risks incurring (see Ravnsborg, cited above, § 30; Putz, cited above, § 31; T. v. Austria, no. 27783/95, § 61, ECHR 2000-XI; Kubli, cited above; Jurík v. Slovakia (dec.), no. 50237/99, 18 March 2003; Kyprianou, cited above, § 31; Zaicevs v. Latvia, no. 65022/01, § 31, ECHR 2007-IX (extracts), and Veriter v. France, no. 25308/94, Commission decision of 2 September 1996, Decisions and Reports (DR) 86-B, pp.