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Ad Michal Ryška:Mysledm, že slovenskfd daS si je v?dom toho, že vfdrok ?. 2 je suokktvfdm tvrzenedm (navedc nep?esnfdm) – viz detailned argumentace v bod? 37 ne1lezu. Bod 38 ne1lezu je tak podle m? t?eba ?edst ve spojened s bodem 37. I v bod? 38 ne1lezu je navedc daS p?i pauše1lnedm posouzened cele9ho ?le1nku opatrnfd, když uve1ded: “V prerokfavanej veci bola intenzita ze1sahu do pre1va s?ažovate?a podstatne1, pretože išlo o ?le1nok novine1ra, ktorfd sa tfdkal ote1zok verejne9ho ze1ujmu, kritiky rozhodovacej ?innosti sfadov a V Zc1SAD? išlo o hodnotovfd sfad.” (d?raz dopln?n) Ad “Alexyho ve1žedced formule”:O to, zda je (?i v?bec m?že bfdt) t?eted prvek testu proporcionality objektivned, se vedou dlouhe9 teoreticke9 disputace. Na podobnou kritiku ostatn? reaguje i Alexy v ?le1nku citovane9m slovenskfdm daS (Alexy, R.: Balancing, constitutional review, and representation, I.CON, Volume 3, Number 4, 2005. s 572 a nasl.). Podle m? je ale Alexyho formule po?e1d p?esv?d?iv?jšed než kejkle ?eske9ho daS s hodnotovfdm, syste9movfdm, empirickfdm a kontextovfdm argumentem [viz Ne1lez Pl. daS 4/94 “Anonymned sv?dek”]. Že je tento test nepoužitelnfd potvrzuje i skute?nost, že se jedm daS ?edded jen, když se mu to hoded.
Podle me9ho ne1zoru lze nepoloženedm p?edb?žne9 ote1zky porušit jak utosnavened ?l. 36 odst. 1, tak utosnavened ?l. 38 odst. 1 Listiny.V te9to v?ci se ale podle me9ho jednalo pre1v? o porušened ?l. 36 odst. 1, protože jde v podstat? o nevypo?e1danou ne1mitku – tj. nedostate?nost, nene1ležitost od?vodn?ned.Porušened ?l. 38 odst. 1 by naopak mohlo nastat tehdy, pokud by šlo o ze1sadned a kvalifikovane9 pochybened p?i rozhodove1ned o položened p?edb?žne9 ote1zky. To m?že spo?edvat ve sve9volne9m ?i na prvned pohled zcela nespre1vne9m nepoložened p?edb?žne9 ote1zky Soudnedmu dvoru, nap?edklad za situace, kdy m?l soud se1m o interpretaci komunite1rnedho pre1va pochyby a p?edb?žnou ote1zku p?esto nepoložil.Z hlediska pre1va na ze1konne9ho soudce je totiž d?ležitfd vfdsledek (položit/nepoložit), zatedmco z hlediska spravedlive9ho procesu zp?sob vypo?e1de1ned se s ne1vrhem (?i v?bec s ote1zkou evropske9ho pre1va, pokud ne1vrh nepadl).Ne1lez podle m? ob? kategorie medche1 dohromady a konstatuje porušened pre1va na ze1konne9ho soudce už v situaci, kdy jde pouze o zp?sob od?vodn?ned (?e1dnost od?vodn?ned je p?itom vfdznamne1 z hlediska ?l. 36 odst. 1). Che1pu sice ze1jem vyhnout se použited zprofanovane9ho a v d?sledku judikatury daS rozplizle9ho ?l. 36 odst. 1 a op?edt rozhodnuted o specifi?t?jšed utosnavened, ale zrovna v tomto p?edpad? to IMHO nebylo namedst?.Ale prakticky to moc vfdznam neme1.
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