Sound administration and functioning of municipalities require more than the relevant legal regulations: officers with up-to-date knowledge are also required. The functioning of local governments implies regular liaising with various central public bodies; thus, they have an important role in balanced public administration. The results of their legislation are local regulations that are as obligatory as any other legal regulation in Hungary - having regard to the proper application of the hierarchy of the sources of law -; noncompliance with them leads to the establishment of legal liability. It is, however, not only the local governments that are entitled to decree-making, the Government, the Prime Minister, the Ministers, the National Bank of Hungary and the heads of autonomous regulatory bodies may also make decrees, and we must also mention extraordinary sources of law which are applied in situations where the state does not function as usual, i.e. they enable governance by decree during a crisis, then they usually become ineffective. The place of such legal sources in the hierarchy and the relationship between them are specified by the Fundamental Law of Hungary.
"Acting within their functions, local governments shall adopt local government decrees to regulate local social relations not regulated by an Act, and/or on the basis of authorisation by an Act. No local government decree shall conflict with any other legal regulation."[2] In addition to the Fundamental Law, the same topic is regulated, amongst others, by Act CLXXXIX of 2011 on Local Governments in Hungary (hereinafter referred to as the Local Governments Act), Act CXXX of 2010 on Legislation (hereinafter referred to as the Legislation Act) and Decree No. 61/2009. (XII. 14.) of the Minister of Justice and Law Enforcement on Legislative Drafting (hereinafter referred to as Legislative Drafting Decree).
Local governance is the result of the decentralisation of the state; self-determination, autonomy are its cardinal components. One of the main segments of their activities is decree-making, which requires extraordinary precision and care[3]. The purpose of my paper is to analyse, interpret this precision-requiring habit and to provide proposals for eliminating arising issues, irregularities. I will discuss the place of local decree-making in the hierarchy of the sources of law, its legislative gravity, and I would like to present the most common cases of negligence in local legislation.
Local governments appear in connection with the decentralisation of the state; the most important of its conceptual components is self-determination, as they perform some kind of self-administration. It is also to be emphasised that it is controlled by a community of people the decisions of which are mandatory for the groups belonging to the community. The past years, decades have seen many types of self-government, such as the self-government of institutions, public corporations, advocacies, national minorities, religious communities, etc.; I will, however, focus solely on local governments in this paper. Local governments -the holders of local public authority - have two types: territorial, county governments (this includes cities with county rights and the local government of the capital) and municipal governments (or governments of parts of municipalities); I will study the decrees made by the latter ones. The system of municipal governance in Budapest should be mentioned, because it has two levels. It consists of a capital city government, which is both a municipal
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and territorial government, and 23 district governments which function as municipal governments.
Looking at their organisational structure, one can see that the responsibilities and powers are held by the municipal council which performs both public administrative tasks and voluntary tasks. At the county level, this body is called the General Assembly which is assisted by the county government office. The local council is chaired by the mayor who is elected by the municipality's community in the year following the year of parliamentary elections. The case is different on the county level, because the chairperson of the county assembly is appointed by and from the members of the county council for a specific mandate. Next, vital, bodies are the committees, which are set up according to a cardinal law, the Local Governments Act. We should also mention the municipal clerk (jegyző), who is an executive officer and plays a key role in decree-making, together with the already mentioned local council. The cooperation of these bodies constitutes the local government, a segment of municipal administration.
Local governments and public bodies have a quite intertwined relationship nowadays, the decentralisation has resulted in a quite complex model. The Local Governments Act regulates such relationships in detail[4]:
Among the different relationships, that with the Parliament should be mentioned, because this body makes the fundamental rules for the legal status, responsibilities, powers, different bodies and management of local governments, gives the guarantee for their operations and ensures their material means. In addition, the Parliament decides, upon the proposal of the Government, in the dissolution of local councils that operate in conflict with the Fundamental Law. The mayor concerned must be invited to the discussion of such an agenda item; the Parliament also decides on the territorial division of the state, and (after hearing the opinion of the municipalities concerned), the merger, division of counties, alteration of their borders, names and seats, and the establishment of districts in the capital city.
The President of the Republic also plays a cardinal role, which is specified exhaustively by the Local Governments Act:
(a) he/she decides on the granting of the city title at the initiative of the local governments concerned, and the establishment, merger of townships, the dissolution of merged townships, the name of cities, townships;
(b) he/she instructs the head of the government office having jurisdiction over the municipality in question (if the Parliament dissolves the local council) to exercise the responsibilities and powers that are vested in the mayor by any law, make decisions in urgent cases that fall within the transferable powers of the local council until the election of the new local council.
The Government shall ensure legal supervision of local governments through the government office, under the instruction of the minister responsible for the legal supervision of local governments.
The role of the minister responsible for local governments should also be mentioned; his/her responsibilities are also listed exhaustively in the Local Councils Act:
(a) he/she participates in the preparation of bills, legal instruments of state administration and specific state decisions concerning the responsibilities and powers of local governments, the activities of mayors, the lord mayor, government offices;
(b) he/she participates in the granting of government support for specific borrowing transactions and other commitments of the local government;
(c) he/she coordinates the settlement development, management activities associated wit the functioning of local governments, and the government responsibilities related to certain databases;
(d) he/she coordinates the calls for tenders to utilise the development funds made availa-
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ble to local governments and the setting up of legal prerequisites of the management of local governments;
(e) he/she participates in the collection, organisation of data from local governments for the funding system of the responsibilities of local governments and the preparation of government decisions;
(f) he/she is entitled to order onsite audits of the state treasury, focusing on the financial management of local governments;
(g) he/she is entitled to access and organise all data pertaining to the subsystem of local governments in public finances;
We should also mention the minister responsible for the legal supervision over local governments, who has the following responsibilities -in combination with the minister responsible for local governments:
(a) he/she directs the legal supervision over local governments;
(b) he/she suggests the submission of a motion to Parliament for the dissolution of a local council that operates in a manner inconsistent with the Fundamental Law of Hungary to the Government;
(c) he/she prepares decisions falling within the competence of Parliament and the President of the Republic;
(d) after studying the proposition of the government office, he/she suggests that the Government invites the Constitutional Court to revise the consistency of a local government decree with the Fundamental Law.
We can also mention the minister, who has quite a broad scope of powers within that of his/her responsibility:
(a) he/she defines the technical rules for the performance of the public administrative responsibilities of mayors, the lord mayor, the chairperson of the county council, the municipal notary and the government office, and checks the effectiveness of such rules;
(b) he/she regulates - in consideration of the available funds - the technical requirements for the operation of institutions funded by local governments, the qualification requirements of the staff of such institutions and checks the effectiveness of such requirements;
(c) he/she notifies the local government of the result of the checks mentioned in Points (a) and (b), provides propositions for the elimination of shortcomings; he/she may suggest that the local council discusses the findings of such checks; he/she notifies the minister responsible for local governments and the government office of any infringement of the law;
(d) he/she notifies the local government of the objectives set by central sectoral policies, the o regulatory instruments, and he/she provides them with the information they require to perform their sectoral responsibilities;
(e) in performing his/her sectoral responsibilities, he/she may request data and information from local governments which are obliged to fulfil such requests;
(f) he/she may provide financial aid to the local government under the legal title and the conditions specified in the act on the core budget - under the coordination of the minister responsible for local governments.
Finally, they are also in contact with national alliances of local governments, which may suggest legislation, actions, consult the Government in strategic issues concerning the system of local governments and the public services provided by local governments and the local government aspects of the core budget.
We can, therefore, see that local governments get in contact with several public bodies in performing their activities, responsibilities, and such bodies control and support their operations.
The previous Point made it clear that the operational self-determination of local governments is partial only, because they are in contact with public bodies in several aspects, and they must comply with the requirements set by such bodies. This idea is supported by the institution of legal supervision, which is obviously required in terms of constitutionality and means much more effective instruments than the previous legality review. Review,
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control means a much weaker connection between the local government and public bodies, while supervision already implies the option of intervention, and, for the local governments, it means economic, financial and state supervision in part. Assets of local governments consist of two main segments: core assets and business assets. They are free to decide how they wish to use the latter one, so the state does not supervise that part, but the state has an influence through the system of borrowing and the funding of responsibilities.
The local government decree is such a legal act that the local government makes under statutory authorisation in accordance with local specificities and to regulate social affairs that are not regulated by higher-level legislation.
Having regard to the fact that local government decrees may not be in conflict with any legal regulation of higher level, it is the fundamental obligation of local governments to adapt their local decrees to the changes in national law so that they can comply with both national and EU laws. Decree-making itself may be initiated by the law or a suggestion of a practitioner of law or the motion of the local council. It must be stressed that the territorial scope of such laws covers only the administrative area of their respective municipality. "In case of local government decrees, it applies to natural persons, legal entities and organisations without a legal personality within the administrative area of the local government; in the case described in Paragraph (la) of Section 5, it applies to the natural persons, legal entities and organisations without legal personality within the administrative area of local governments members to an association of local governments; in the case described in Paragraph (lb) of Section 5, it applies to the natural persons, legal entities and organisations without legal personality within the administrative area of local governments members to the association of local councils."[5] The person preparing a piece of legislation must perform a preliminary impact assessment to assess the expected consequences of the regularisation. If the preliminary impact assessment is performed for a local government decree, then the council of the local government must be informed of its result. The preparatory phase might be different from time to time, because in most of the cases it is the subject-matter of the local government decree that determines the organisation which will perform the preparation; however, I do not want to say here that this could make the notary obsolete, because this is actually excluded by the law; however, it is not against the law - moreover it is sometimes obvious - that a professional organisation participates in this procedure.
The impact assessment must study the different impulses such as the social, economic, budget effects, the necessity of the piece of legislation in question, the consequences in case it is not made, the reason for making it and the personnel, material and financial requirements of applying it. If the draft decree is ready, then the next step is opinionating. Depending on the subject-matter of the decree, opinionating might consider different bodies, organisations. Opinions might come from the committees, legal practitioners, residents (if the draft decree is made available for public inspection), and social organisations may also play a special role.. Finally, the draft decree is submitted to the local council, and it is the municipal notary who plays the greatest role in a professional submission. Decrees are usually adopted in two rounds, then the notary drafts the final decree, then both the notary and the mayor sign it. Finally, the piece of legislation is uploaded to the website of the municipality and the website of njt.hu and is promulgated in the locally usual way. Local decrees are on the bottom of the hierarchy of the sources of law, hence local government decrees may not be inconsistent with any other legislation. As prescribed by the Fundamental Law, the local government sends the decree to the government offices of the capital city and the counties immediately after the promulgation. "If the capital or county government office finds the local government decree or any of its provisions to be in conflict with any legal regulation, it may initiate a judicial review of the local government decree.
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The capital or county government office may apply to a court for the establishment of non-compliance of a local government with its obligation based on an Act to adopt decrees or take decisions. Should the local government fail to comply with its obligation to adopt decrees or take decisions by the date determined by the court in its decision establishing non-compliance, the court shall, at the initiative of the capital or county government office, order the head of the capital or county government office to adopt the local government decree or local government decision required to remedy the non-compliance in the name of the local government."[6]
The Government ensures - through its Department of Legal Supervision - the legal supervision over local governments through the government offices of the capital city and the counties. The purpose of legal supervision is to investigate the lawful operation of the council, committees, mayor, municipal notary, partial local government, association (if any) of the local government. The supervisory toolset is quite diverse, the one I would like to examine in detail is the scheme related to decree-making.
The Local Governments Act specifies it as follows: "If a local government decree conflicts the Fundamental Law of Hungary, then the government office shall suggest - through the minister - the revision of the decree in question by the Constitutional Court to the Government, if the legality appeal or initiative failed in terms of convoking the local council or the council of association, and - in the case specified herein - convocation of the local council or the association council was fruitless.
The government office shall send the draft motion both to the minister responsible for the legal supervision over local governments and to the local government concerned.
The Government Office may suggest the revision of the compliance of the local government decree with the relevant piece(s) of regulation to the Kúria (Supreme Court of Hungary). Concurrently with the launching of the court proceedings, the Government Office shall send the motion to the local government concerned."[7] It may be concluded that a local government decree may be sent to two constitutional bodies after its adoption, to the Constitutional Court for the inspection of its consistency with the Fundamental Law, to the Kúria for the inspection of its consistency with other piece(s) of legislation. Local governments may, however, make not only decrees but decisions as well, which are then revised (if necessary) by the relevant administrative and labour court.
It may be concluded that the process of decree-making is quite complex and the supervision over it can make a great impact on it nowadays, as we can meet unmindful legislators rarer, although legal supervision has also not created perfect and flawless local decree-making, we can still meet decrees that are unclear - either or both formally and substantively -, uninterpretable, their elimination is however of key importance, as the potential unmindfulness, technical imperfections of the legislator may cause that both the legal practitioner and the person(s) to whom the law applies suffer negative consequences, they might experience injustice, the result of which might be legal uncertainty. It is not perfectly implemented even despite the existing legal supervision. In the following, I would like to study the effectiveness of relevant legislative criteria, according to the relevant provisions of the Legislation Act and the Legislative Drafting Decree.
A very important stage of controlling local government decrees closed in 2011, because in 2012, the Local Governments Act implemented significant reforms which all local governments had to and must comply with, equivalently. The purpose of this study is to draw attention to the elimination of imperfections made by smaller or larger local legislators, to provide guidance towards precision and compliance with the law. Unfortunately, imperfections of legislation occur quite often at the central level; however, they occur even more often and are more diverse on the level
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of local governments, where one can find real "gems" among the products of legislation.
There are municipalities where the Rules of Organisation and Operation (hereinafter: ROO), the decree on the municipal budget -adoption of which is mandatory - are not adopted, or any obligation to make a decree in any other subject matter is not fulfilled at all; one can meet many of such municipalities. A good example of this is Dömsöd in Pest county; this municipality does not have a ROO on the njt.hu website, but has uploaded it to its own website.[8] The same happened in Halásztelek as well. Dióspuszta in Baranya county is in a different situation, its decrees are not uploaded either to the official website or the local one. I have seen the same in case of Mecsekszakál as well.
One has every reason to ask how is this possible, given the fact that there is legal supervision nowadays, and how long can this be?
Deregulation, a concept of law, means the containment of legal regulation; it purpose is to reduce the number of pieces of legislation, cancel, rescind obsolete legislation; this contributes to the simplification, better transparency of the law. The legislator (who is the municipal notary in this case) and the local council should not focus on regulation only; they are also obliged to cleanse, and so protect, the legal order of pieces of legislation, legislative regulations that have become obsolete for any reason. Keeping obsolete pieces of legislation in force would make the legal order unclear after a time, and this would deteriorate the effectiveness of the requirement of legal certainty. This point is closely linked to the previous paragraph, because there are settlements with multiple decrees still in force. One can obviously ask, which is applicable among the many decrees in force? Such is Babarc[9] in Baranya county, where the decrees on the municipal budget for 2015, 2016 and 2017 are still in force and the municipality has not got an online site. Csertő or Dány (in Pest county) are in a similar situation, as all their decrees on their respective annual budgets are accessible and in force since 2014; moreover, I have not found an online site for the municipality of Csertő, but I did find one for Dány; however, the decree on the annual budget and the ROO had not been uploaded in this case either.
The Schedule to the Legislative Drafting Decree provides guidance on the numbering of decrees:
".../... . (........) önkormányzati rendelete" (in English: Local Government Decree of ".../... . (........))
Studying local legislation, one can find multiple variants of this marking. Even despite the fact that there is a clear template according to which a "/" sign should divide the number of the decree from the year, then the year should be followed by a point; the date is written in a way that the month is written with Roman numbers, the day is written with Arabic numbers (between round brackets), then comes the expression "local government decree" - excluding any variants of abbreviations. The legislative body may be indicated in two ways, either the local council itself or the municipal general assembly. In the following, I give an example of correct numbering for each case:
- Szekszárd Megyei Jogú Város Önkormányzata Közgyűlésének 27/2014.(XII.23.) önkormányzati rendelete (In English: Local Government Decree No. 27/2014. (XII. 23.) of the Municipal General Assembly of the Local Government of Szekszárd, City with County Rights)
- Dombiratos Község Önkormányzat Képviselő-testületének 6/2011. (IV.13.) önkormányzati rendelete az Önkormányzat Szervezeti és Működési Szabályzatáról (in English: Local Government Decree No. 6/2011. (IV. 13.) of the Local Council of the Local Govern-
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ment of Dombiratos on the Rules of Organisation and Operation of the Local Government)
I must, however, mention that the numbering is different from the foregoing in many cases, often due to typos made due to inattention. For example:
- "Ipolydamásd Község Önkormányzat Képviselő-testületének 9/2014 (XI.21..) önkormányzati rendeleteb AZ ÖNKORMÁNYZAT SZERVEZETEI ÉS MŰKÖDÉSI SZABÁLYZATÁRÓL" (In English: Local Government Decree No. 9/2014 (XI.21..) of the Local Council of the Local Government of Ipolydalmásd[10] It is clearly visible what criteria the title does not meet. The legislative body is correctly named, then there is no point after the year, the date is also written incorrectly, finally, they use the expression "önkormányzati rendeleteb", which is (i.e. the "b" at the end) presumably a typo. It may be concluded that such issues could have been prevented with a bit more attention and care
- "Nyíregyháza Megyei Jogú Város képviselő-testület 18/2017. (IV.28.) A helyi iparűzési adóról" (In English: 18/2017(IV.28.. ) of the Local Council of Nyíregyháza, City with County Rights on the Local Business Tax)[11] The seat of Szabolcs-Szatmár-Bereg county is Nyíregyháza; since it is a city with county rights, its local government decree is not adopted by the Local Council but the Municipal General Assembly - i.e. the legislative body has been indicated incorrectly. Moreover, there is no point after the year, but there are even two after the date, and the expression "önkormányzati rendelet" is also not written.
- I have found another typical mistake in one of the decrees of Nyíregyháza, City with County Rights: "NYÍREGYHÁZA MEGYEI JOGÚ VÁROS KÖZGYŰLÉSÉNEK 27/2003. (V. 29.) számú rendelete a nem lakás céljára szolgáló helyiségek bérletéről" (In English: Decree No. 27/2003. (V. 29.) of the Municipal General Assembly of Nyíregyháza, City with County Rights on the Renting of Non-residential rooms")[12] The legislator inserted the expression "számú" (No.) in addition to the mandatory components, which is a mistake, of course.
- In case of Pincehely, the ROO is not available on the official website, but it can be downloaded from the website of the municipality; the marking of the decree lacks quite some components: "Pincehely Nagyközség Önkormányzata Képviselő-testületének ...../2014.(XI.) önkormányzati rendelete Pincehely Nagyközség Önkormányzata Képviselőtestületének Szervezeti és Működési Szabályzatáról" (In English: Local Government Decree No....../2014.(XI. ) of the Local Council of the Local Government of Pincehely) The serial number and the date of the decree, which are mandatory components, are missing from the marking of the decree.
- "Létavértes Városi Önkormányzat Képviselő-testületének 4/2014.(II.11.) Ör. számú rendelete A köztisztviselők munkavégzéséről és juttatásairól szóló rendelet megalkotása" (In English: LGD No. 4/2014.(II.11.) of the Local Council of the Local Government of Létavértes on the adoption of the decree on the Work and Remuneration of Civil Offic-ers)[13] The marking of this decree is again deficient, because the application of the abbreviation "Ör." (LGD) for "önkormányzati rendelet" (local government decree) is forbidden; moreover, I have already explained compliance with the law regarding the expression "számú" (No.).
- "Város Önkormányzata Képviselő-testületének 1/2005 (I.20.) önkormányzati rendelete a településrendezési feladatok megvalósítását biztosító sajátos jogintézményekről" (in English: Local Government Decree No. 1/2005 (I.20.) of the Local Council of the Local Government of City)[14] The following example does not define the city the Local Council of
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which adopts the local government decree, and there is no point after the year. (Hajdúszoboszló)
In addition to the examples shown in this paper, we could find several examples on the official internet website; in addition to the examples, some of the titles have spelling errors, some of them do not have a year or the point after the date, as it is prescribed by the rules of Hungarian spelling. What I wanted to show in my paper was the most typical mistakes.
Pieces of legislation can usually be divided into the following parts: preamble, introductory part, general and detailed provisions, final provisions and schedules. Local decrees also have the same parts, the only difference is that, subject to Paragraph (1) of Section 51 on the Legislative Drafting Decree, the local government decree may not have a preamble. The preamble is a solemn-sounding introductory part which summarises the objectives of the legislator. According to Paragraph (1) of Section 51 of the Legislative Drafting Decree, the preamble is a logical unit with no normative content in the piece of legislation, it should be applied in acts of Parliament to be adopted within the scope of legislation defined in the Fundamental Law. Paragraph (2) Acts of Parliament to be adopted within the scope of legislation defined in the Fundamental Law shall have a preamble. Paragraph (3) The preamble can be used to describe be background, reason and purpose of the regulation, lay down such principal, theoretical statements that cannot be settled in the sections of the bill due to their lack of normative content. According to the foregoing, only acts of Parliament and draft amendments to the Fundamental Law can have a preamble. Therefore, decrees have an introductory part which also does not have a normative content. The normative content is necessary for the adoption of the piece of legislation, it enumerates the components of validity specified in the relevant subtitle and an expression referring to the legislative act. Legislative powers can, therefore, be original or derivative. Examples for this:
Original: "Ipolytölgyes Község Önkormányzat Képviselő-testülete a Magyarország helyi önkormányzatairól szóló 2011. évi CLXXXIX. törvény (a továbbiakban: Mötv.) 143. § (4) bekezdés a) pontjának felhatalmazása alapján, a Magyarország Alaptörvénye 32. cikk (1) bekezdés d) pontja szerinti feladatkörében eljárva a következőket rendeli el:" (In English: Under authorisation by Point (a) of Paragraph (4) of Section 143 of Act CLXXXIX of 2011 on Hungary's Local Governments (hereinafter referred to as Local Governments Act) and acting within its responsibility defined in Point (d) of Paragraph (1) of Article 32 of the Fundamental Law of Hungary, the Local Council of the Local Government of Ipolytölgyes orders the followings:[15]
Derivative: Under authorisation by Paragraph (2) of Section 1, Paragraph (1) of Section 10, Point (b) of Paragraph (3) of Section 25, Section 26, Point (b) of Paragraph (1) and Paragraph (3) of Section 32, Section 45, Paragraph (4) of Section 48, Paragraph (2) of Section 58/B of Act III of 1993 on Social Governance and Social Benefits, Paragraph (2) of Section 18, Paragraph (1) of Section 131 of Act XXXI of 1997 on the Protection of Children and the Administration of Guardianship, and Paragraph (5) of Section 74 of Act CXL of 2004 on the General Rules of Administrative Proceedings and Services, acting within its responsibility defined in Point (a) of Paragraph (1) of Section 32 and Paragraph (1) Section 13 of Act CLXXXIX of 2011 on the Local Governments of Hungary, the Local Council of the Local Government of Hajduszoboszló City adopts the following decree:"[16]
It may be concluded that the number of local governments applying a preamble in their local decrees is quite small, but one can still find some gems: The following ROO has, for instance, a preamble:
"Cibakháza is in Jász-Nagykun-Szolnok county, south of Szolnok, the county seat, on the left bank of the Tisza river, in the southwest of the county, in the Tiszazug subregion. It is accessed on Road No. 442, which goes through it.
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It was first mentioned on an official document in 1465; historical sources, however, imply that it was a habited region already during the 11[th] to 14[th] century. Cibakháza, which was mentioned as a market town from the beginning of the 16[th] century, was destroyed during the period of Turkish occupation, its rebuilding started after 1717. As the most important catholic township of the Tiszazug subregion, it became the ecclesiastical centre of the region. This important crossing and tolling place got back its rank as a market-town in 1832. It had a special strategic role during the war of independence of 1848-1849.
The population is mostly catholic, the backbone of its economics is farming and animal husbandry, it has piped drinking water, natural gas, sewage, cable television and a modern telephone network.
The number of permanent residents in the township on 1 January 2010 was: 4437.
The Local Government of Cibakháza conducts its public affairs in a self-determined, free, democratic way, with broad publicity; it provides public services, exercises local powers, arranges for the resources for this, and supports the self-organising communities of its population."[17] In this case, the preamble tells us about the past of the township, the religious ideology of the population and the assets of the township, such as the sewer network, but we cannot read a word about the background, purpose or reason of the regulations - which would be the actual point of a preamble. There is another township that applied the preamble with a similar content. In ROO No. 7/1997. (IV.17.)[18], Bogyiszló used it as an introductory part mapping the population. As I have, however, already mentioned, this may not be the part of local government decrees; still, its application could be worthy of consideration in case of decrees that either grant titles of honorary citizenship or decorate people.
Another decree I would like to mention in this section is that of Tahitótfalu[19], because it has such a solution that is not regulated by any piece of legislation. The legislator of the township, after providing the title of the decree and the establishment of its legislative powers, provides a table of contents for the chapters of the decree.
According to Paragraph (2) of Section 40 of the Legislative Drafting Decree, "the title of Chapters is as follow (in the following order)
(a) the serial number of Chapters (positive whole integers) are written with Roman numbers,
(b) the names of the types of structural units are written with a big starter, and
(c) the title of Chapters are written with a big starter.
In addition, Point 3.2 of Schedule No. 1 of the relevant piece of legislation discusses the writing of the foregoing, as follows: "(the (integer) number of the Chapter with Roman numbers). Chapter (Chapter title with big starter)"
Many decrees lack the indication of chapters. For example:
- "Bénye Község Önkormányzat Képviselő testületének 5/2014 (XI.12.) számú önkormányzati rendelete az önkormányzat és szervei Szervezeti és Működési Szabályzatáról (In English: Local Government Decree No. 5/2014. (XI.12.) of the Local Council of the Local Government of Bénye on the Rules of Organisation and Operation of the bodies and organisations of the Local Government[20]
- "Jászladány Nagyközségi Önkormányzat Képviselő-testületének 6/2015. (II.23.) önkormányzati rendelete A szervezeti és működési szabályzatról" (In English: Local Government Decree No. 6/2015. (II.23.) of the Local Council of the Local Government of Jászladány on the Rules of Organisation and Operation[21]
There are many cases where decrees are - correctly - divided into chapters, but the way it is done is not correct:
"CHAPTER I ORGANISATION AND OPERATION OF THE LOCAL COUNCIL
CHAPTER II COMMITTEES OF THE LOCAL COUNCIL
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CHAPTER III THE MUNICIPAL COUNCILOR
CHAPTER IV THE MAYOR CHAPTER V/A THE VICE-MAYOR
CHAPTER V/B Cooperation with the Roma Minority Government
VI THE MUNICIPAL NOTARY
Drafting CHAPTER VII Rescinded *20
CHAPTER VIII ASSOCIATIONS OF THE LOCAL GOVERNMENT
CHAPTER IX LOCAL REFERENDUM, PEOPLE'S INITIATIVE
CHAPTER X THE PROPERTY OF THE LOCAL GOVERNMENT
CHAPTER XI FINAL PROVISIONS AND INTERPRETATION *7"[22]
The ROO of Fegyvernek does not comply with the points of the Legislative Drafting Decree, because the term "chapter" is completely capitalised, and it has Chapters V/A and V/B, which is completely incorrect. In addition, the content of Chapter VII is missing entirely. In addition, it has uninterpretable parts of text, such as "szerkesztés" (drafting, edition) which appears more than once in the text of the decree.
The ROO of Egervölgy has only one chapter. "Chapter I The local government and its responsibilities"[23]
The decree on the municipal budget in case of Balassagyarmat is a decree that has chapters, however, it must be mentioned for a tiny piece of negligence: "I. fejezet, II. fejezet III. fejezet, IV. fejezet, V. fejezet VI. fejezet, VII. fejezet, Vegyes zárórendelkezések" (In English: "Chapter I, Chapter II Chapter III, Chapter IV, Chapter V Chapter VI, Chapter VII, Miscellaneous final provisions")[24] One can see that the legislator ignored Point (c) referred to in the foregoing, and did not indicate the last part as a Chapter. Salgótarján, however, applies a very specific solution: "ELSŐ FEJEZET (CHAPTER ONE), MÁSODIK FEJEZET (CHAPTER TWO), HARMADIK FEJEZET (CHAPTER THREE), NEGYEDIK FEJEZET (CHAPTER FOUR), ÖTÖDIK FEJEZET (CHAPTER FIVE) HATODIK FEJEZET (CHAPTER SIX) HETEDIK FEJEZET (CHAPTER SEVEN), NYOLCADIK FEJEZET (CHAPTER EIGHT)"[25] In case of Nagykörős, however, the indication of chapters is missing entirely, titles are written with Arabic numerals: "1. Általános rendelkezések (1 General Provisions), 2. A költségvetés főösszegei, főösszegek részletezése (2 Total amounts of the budget, breakdown of these total amounts), 3. Eljárási szabályok (3 Rules of procedure), 3. Szakaszok jelölése (3 Indication of sections), 4. A költségvetés végrehajtásának ellenőrzése (4 Controlling the implementation of the budget), 5. Záró rendelkezések (5 Final provisions)"[26] In case of Balatonboglár, chapters were indicated as follows: "ÁLTALÁNOS RENDELKEZLÉSEK (GENERAL PROVISIONS), II. FEJEZET (CHAPTER II), III. Fejezet (Chapter III), IV. Fejezet (Chapter IV)"[27]
The drafting of "Local Government Decree No. 11/2014. (X. 17.) of the Local Council of the Local Government of Besenyőd on the Rules of Organisation and Operation of the Local Government of Besenyőd"[28] did also not comply with the requirements, because it has two second chapters, and the each letter of the structural units are capital letters, which also conflicts legislation.
a) "I. Fejezet ÁLTALÁNOS RENDELKEZÉSEK" (Chapter I GENERAL PROVISIONS)
b) "II. Fejezet AZ ÖNKORMÁNYZAT SZERVEI, AZ ALPOLGÁRMESTER ÉS A BIZOTTSÁGOK" (Chapter II BODIES OF THE LOCAL GOVERNMENT, THE VICE MAYOR AND THE COMMITTEES)
c) "II. Fejezet A KÉPVISELŐ- TESTÜLET MŰKÖDÉSE" (Chapter II FUNCTIONING OF THE LOCAL COUNCIL)
d) "III. Fejezet ZÁRÓ RENDELKEZÉSEK" (Chapter III FINAL PROVISIONS)
Pursuant to Section 42 of the Legislative Drafting Decree, "Sections are indicated in the following order:
(a) the Arabic serial number of the section, consisting of positive integers and
(b) the sign §."
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This piece of legislation stresses that sections must be indicated with Arabic serial numbers, implying a consecutive, continuously increasing numbering. In the drafting of the ROO of Egervölgy, a mistake was made in the sequence of the sections, because section three, four and five are missing, and the first section sign is followed by a point. "1. §. 2. § 6. § 7. § 8. § 9. § 10. § (...) etc."[29]
The level of disorderliness in the decree of Örményes is quite high, because the first section is indicated with a Roman number, then section two, three and four are completely missing. We have a section ten, but without a content "I. § 5. § 7. § 10. § (no content) 11. §(...) 16. § 18. §(...) etc."[30]
The legislator of Fegyvernek regularly puts a point after the section sign and the structure is absolutely disorderly, because chapters are indicated wrongly, so are sections, the indication of paragraphs changes all the time, points are also indicated wrongly, the increasing sequence is not perfect, there are missing numbers.
"I. FEJEZET A KÉPVISELŐTESTÜLET SZERVEZETE ÉS MŰKÖDÉSE (CHAPTER I ORGANISATION AND OPERATION OF THE LOCAL COUNCIL
1. Responsibilities and powers of the local government
6. §. (1) In addition to the mandatory responsibilities defined in the Local Governments Act, the Local Government may take voluntary responsibilities as well:
a. / In its Economic Programme
b. / in its annual budget
c. / based on an ad-hoc decision, the funding of which may be ensured by modifying the budget.
2. The Local Government defines the scope of responsibilities (required by law, voluntary) in its Economic Programme, annual budget.
3. The sequence of task-implementation:
a. / the local government shall implement responsibilities defined by the local governments act;
b. / implementation of responsibilities voted for on local referenda;
c. / tasks in its Economic Programme;
d. / other responsibilities may be fulfilled after that.
(4) Mandatory and voluntary tasks of the Local Government are in Annex 6 of the Decree.
7. §. Rescinded *21
7/A. §. Rescinded *20
2./ Requirements for the organisation"[31]
The legislator of Edve applies the following practice of indication: "1. §. 2, § 3. §. 4,§ 5,§, (...) 15,§."[32] The point and the comma appear here in almost all combinations.
The Local Government of Szeged, City with County Rights writes sections in quite a particular manner, by putting the abbreviation "Ö.r." (LDG) before every section. "Ö.r. 1. § Ö.r. 2. § (...) etc."[33]
It may be concluded that implementation might differ from the regulation; this could be eliminated by follow-up, one-off proofreading after adoption.
In addition, we can see many other solutions as well, such as the Local Government Decree No. 11/2015. (X.13.) of the Local Council of the Local Government of Gánt on the amendment of Decree No. 9/2005. (VII. 15.) on the Local Building Code"[34], which applies Arabic serials without the § sign. The derogatory omission of the sign ' in this specific decree results in the following sequence of Arabic numbers: 1, 1, 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 1, 1, 2, 3, 4, 5, 6, 7, 8, 9, 1, 2, 1, 1, 2, 3, 4, 5, 6, 3, 1.
On the grounds of Section 44(4) of the Legislative Drafting Decree: "the numbering of paragraphs should restart in each section, and should be realised using positive integers in the form of Arabic numerals written between brackets within each section." It must be stressed that the Legislative Drafting Decree understands the brackets as round brackets. There are many examples for the inaccurate application of this section.
It is likely that a lot of legislators have made the mistake of not reading the schedule to this piece of legislation, because the decrees
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provide a complete repertory of brackets; what is more, it also happens that brackets are not used at all.
The legislator completely omitted rounded brackets in the ROO of Székesfehérvár, City with County Rights. "1. 2. 3. 4. etc."[35]
In the case of Hajdúszoboszló, the legislator writes the serial number between two "/" signs instead of round brackets; what is more, the legislator sometimes adds letters to them, which is, of course, incorrect. In other cases, the legislator writes empty paragraphs.
"5. § /1/
/2/ In case the connection to the sewer network is made subsequently, the part payable by the residents is included in Schedules 1 and 2.
/2a/ The contribution payable by the residents in case of making a connection to the sewer network not included in Schedules 1 and 2 is HUF 20,000/connection.
/2b/ The total amount of the contribution payable by the resident(s) must be paid within 12 months after submitting the application for permission to make a connection to the sewer network.
/2c/ The contribution payable by the resi-dent(s) covers the proportional cost of installing the receiving main pipeline and the ensuring of the option to make the connection.[2]
/3/ For the building of a natural gas pipeline: HUF 30,000/real estate unit
/4/ For road construction/ a/
b/ The primary criteria for assessing the application are the profitability of the investment and the organisation of the building community, expressed in %.
/5/"[36]
In case of Local Government Decree No. 3/2015. (II. 26.) of Csécse[37], this indication is quite varied, it reads as follows in Section 11: "1. 2. 3. 4. (5)".
Similarly, Local Government Decree No. 8/2013. (IV. 19.) on the ROO of Kazincbarcika[38] also has the indications mentioned, but it applies the following indication in Section 12: "1/".
According to Paragraph (1) of Section 37 of the Legislative Drafting Decree, "A draft bill may not have any unmarked structural units.
By virtue of Section 48(1) of the Legislation Drafting Decree "Points may be indicated with the lowercase letters of the Latin alphabet and with the ')' sign or with Arabic serials generated from positive integers.
Paragraph (2) reads: A list longer than fifteen items can have only Arabic numbers as serial numbers.
The text of this piece of legislation clearly implies that every point must be indicated; however, we can meet unmarked paragraphs in several occasions. The decree of Bercel is an excellent example for this, because the legislator marked the points with indents: "11. §. (2) The Local Council shall be entitled to decide:
- the utilisation of any surplus revenues of institutions;
- the utilisation of free funds."[39]
In the decree of Cserhátszentiván, the legislator uses points and the "/" sign to indicate points "12. § The local council shall authorise the mayor to take the measures necessary for continuous operation during the year:
a./ To submit the tender for the call for tenders for "Additional support for preserving the operationality of local governments".
b. / Subject to the realisation of revenues (especially the support applied for in Point a./), to make further measures to maintain liquidity (current account overdraft facility, taking of a payroll loan)."[40]
The Decree of Héhalom has the following solution, and the marking of the paragraph is also wrong in this case:
"/4/ Development expenditures of the local government, broken down for each objective:
Own resources for renovating the kindergarten: HUF 3,333,000
- Renovation of sidewalks: HUF 667,000
- Renovation of the fence of the kindergarten: HUF 525,000 (...)"[41]
Tiszaderzs applies a solution which is quite specific: " 3. § (4): a) b) □ c) □ d) □ (...) etc."[42]
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After each point, it uses a blank square to separate the points from each other - even though the legislator used the right indication.
The Decree of Kőtelek writes the points as follows: "7. § (3): 1.) 2.) 3.) 4.) 5.) 6.)"[43] and they also use letters for marking, following the same logic: a.) b.) c.) (...) etc.
In case of Tahitótfalu, the legislator used both dots and letters for marking, the latter is followed by a point and the "/" sign, in Section ó.
"(1) The Local Council confers the following powers on the Committee of Social Affairs:
- the powers specified in Section 48 of Act III of 1993 on Social Governance and Social Benefits (hereinafter referred to as the Social Act), at first instance (appeals lodged against the decision of the Committee are decided by the Local Council),
- the social care provided in the form of firewood,
- ad-hoc aids, social meals and social care at home and care of the elderly,
- prevention of the endangerment of minors, eradication of already existing endangerment, facilitation of the development of the physical and psychical health of minors in the family,
- social care and mental hygiene care for families, prescribed in separate legislation, and prevention of disfunctions in the family system,
f. / referral to institutions providing personal care.
g. / the powers specified in Local Government Decree No. 3/2015. (II. 26.) of the Local Council on financial and non-financial social and child care."[44]
The ROO of Nyíregyháza indicates points with various markings. The range shows the following:
"Correct indication within 1. § (4): a) b) c) d) e) f)
"Within 19. § (1): a) b) c) d) e) f)
Within 25. § (4): a. b. c)"[45]
A decree of Kübekháza has commas instead of round brackets, except for point e: "13. § (2) a, b, c, d, e"[46]
The legislator of a decree of Székesfehérvár, City with County Rights used a list of more than 15 items, and it did not use serial numbers to indicate such items, which is also a formal defect. "10. § (1) a. b. c. d. e. f. g. (...) n. o. p."[47]
One of the most important criteria of the application of the law, that the legislator determines what will be applied and until when, and that whatever has been rescinded, it should not be applied any more. The question of the starting date of the applicability of a decree is answered by the date of promulgation, having regard to the period required for the preparation. Section 2(3) of the Legislation Act reads: "The date of entry into force of a law must be set in a way leaving time enough to prepare for the application of that law." The Decree of Hódász did not comply with this provision: "(1) This Decree shall enter into force on 15 February 2017." Clause: The Decree was promulgated at 2:00 PM on 15 February 2017."[48] It may be concluded that the time necessary for the preparation for the application of this piece of legislation has not passed. The Legislative Drafting Decree does not prohibit entry into force on the date of promulgation, but it sets out that the date of entry into force must be given as the hour in this case. The decree of Diósjenő[49] for instance, lacks the final provision and the date and time of promulgation and entry into force of the decree.
The Decree of Mátraszele indicates the promulgation as follows:
"6. §. 1. This Decree shall enter into force on the date following its date of promulgation.
(2) The municipal notary shall procure that this Decree is promulgated."[50] In this case, the date of promulgation is not indicated, so the date of entry into force is also not clear, and -referring back to Point c. "Indication of para-
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graphs" - the legislator indicates paragraphs differently, within the same section.
The examples in this paper allow us to make the clear conclusion that all mistakes could be avoided if the legislator prepared each draft decree according to the rules of the Legislation Act and the Legislative Drafting Decree. It is - in my opinion - of key importance that legislators apply and use the mentioned sources of law as cardinal and basically key pieces of legislation; moreover, I would suggest that tests on them are made more pronounced on the mandatory further trainings, and the codifier trainings are made mandatory. In addition, one must say that there are countless defects of aesthetics, typos, that occur due to the transfer to the electronic interface, releasing legislators from the charge of negligence. Though in many cases, a comprehensive check would also improve the quality of a decree. Nowadays we have an operating legal supervision, legislative defects still have a broad repertory, which will, hopefully, become lesser in the future. According to Paragraph (1) of Section 2 of the Legislation Act, it is a fundamental requirement that pieces of legislation have clearly interpretable regulatory content for the person(s) to whom they apply. The application of both substantive and formal rules is therefore important, because it is a primary criterion that pieces of legislation are clear and serve the benefit of the local community, where it is quite difficult (without an elaborate method for the reconciliation of interests), and important to make the persons to whom such laws apply comply therewith, because it is essential that provisions already set out are complied with and applied. ■
NOTES
[1] This paper has been made within the framework of the programmes initiated by the Hungarian Ministry of Justice to raise the standard of legal education.
[2] Fundamental Law of Hungary of 2011, Freedom and responsibility, Paragraphs (2)-(3) of Article 32
[3] Compare with Péter Tilk: Gondolatok a kormányhivatalok vezetőinek önkormányzati rendeletalkotásra vonatkozó (pótlási) hatásköréről. [Thoughts on the competence of heads of government offices to make local government decrees (if missing).] Új Magyar Közigazgatás [New Hungarian Public Administration] 2011/8.; Péter Tilk: A Kúria Önkormányzati Tanácsa helyi jogalkotással kapcsolatos elvárásai. [Requirements of the Local Government Council of the Curia of Hungary regarding local legislation] Kodifikátor Alapítvány [Kodifikátor Foundation], 2014.; Péter Tilk: A helyi rendeletalkotás egyes kérdései a Kúria döntései tükrében. [Certain issues of local decree-making in the light of the decisions of the Curia of Hungary] Kodifikáció [Codification] 2014/1.
[4] Act CLXXXIX of 2011 on the Local Governments of Hungary
[5] Point (b) of Paragraph (2) of Section 6 of Act CXXX of 2010 on Legislation
[6] Paragraphs (4)-(5) of Article 32 of the Fundamental Law of 2011
[7] Paragraphs (1)-(2) of Section 136 of Act CLXXXIX of 2011 on the Local Governments of Hungary
[8] http://www.domsod.hu/rendeletek
[9] http://njt.hu/njt.php?onkormanyzati_rendeletek
[10] http://njt.hu/njtonkorm.php?njtcp=eh2eg1ed4dr1eo0dt1ee0em9cj4by9cb0cb7ca8bz7bw6p
[11] http://njt.hu/njtonkorm.php?njtcp=eh6eg3ed8dr5eo8dt1ee8em3cj6by9bz0bw9ce4cc7bx0b
[12] http://njt.hu/njtonkorm.php?njtcp=eh9eg6ed7dr0eo1dt8ee7em4cj1by0ca5cb4cb7cf2bx7h
[13] http://njt.hu/njtonkorm.php?njtcp=eh7eg8ed1dr4eo1dt4ee9em4cj3by0by7bx6ca3bx6cb5l
[14] http://njt.hu/njtonkorm.php?njtcp=eh9eg6ed3dr2eo9dt8ee9em8cj3bx8by7bw6cb7bw0cd7l
[15] http://njt.hu/njtonkorm.php?njtcp=eh4eg5ed0dr9eo4dt7ee4em7cj2cd1bw0cb9bz6by1e
[16] http://njt.hu/njtonkorm.php?njtcp=eh4eg7ed2dr9eo4dt1ee4em9cj2bx1by2bx9bz8cc5cf2d
[17] http://njt.hu/njtonkorm.php?njtcp=eh5eg6ed5dr4eo3dt0ee7em8cj9cd0cb1bz4ce7bw8k
[18] http://njt.hu/njtonkorm.php?njtcp=eh8eg9ed0dr7eo2dt9ee2em7cj2bx9bw8ce5ce2cd9by0h
[19] http://njt.hu/njtonkorm.php?njtcp=eh0eg9ed2dr3eo0dt3ee8em7cj6by7by2bz5bw8cc5cc6p
[20] http://njt.hu/njtonkorm.php?njtcp=eh6eg7ed0dr7eo4dt5ee2em1cj4ce5bz8bw9bw0cc9e
[21] http://njt.hu/njtonkorm.php?njtcp=eh8eg5ed6dr1eo0dt3ee4em9cj0by1cb2cb9ca6bx7cb6d
[22] http://njt.hu/njtonkorm.php?njtcp=eh2eg1ed6dr1eo8dt5ee2em7cj2by3bx2bw1bw2bx7by2c
[23] http://njt.hu/njtonkorm.php?njtcp=eh6eg9ed6dr5eo0dt7ee0em3cj8ce3cb0ce9bz2cf7g
[24] http://njt.hu/njtonkorm.php?njtcp=eh8eg3ed4dr7eo6dt5ee0em7cj0by5cb4ca7bw6ce1ca2e
[25] http://njt.hu/njtonkorm.php?njtcp=eh6eg3ed2dr1eo4dt3ee8em7cj6by7cb4cd9bw8bx3by2n
[26] http://njt.hu/njtonkorm.php?njtcp=eh6eg1ed4dr3eo0dt7ee0em5cj8by5cb6by3ce8cd5cd4m
[27] http://njt.hu/njtonkorm.php?njtcp=eh2eg5ed4dr1eo4dt1ee2em3cj2by3bx4cd9bx2cc3bw6n
[28] http://njt.hu/njtonkorm.php?njtcp=eh5eg6ed5dr2eo9dt2ee1em0cj5cf8ce3bx2ca5cb8o
[29] http://njt.hu/njtonkorm.php?njtcp=eh6eg9ed6dr5eo0dt7ee0em3cj8ce3cb0ce9bz2cf7g
[30] http://njt.hu/njtonkorm.php?njtcp=eh5eg4ed1dr8eo7dt8ee3em2cj7bx0ca1by8ce9cb0cc3h
[31] http://njt.hu/njtonkorm.php?njtcp=eh2eg1ed6dr1eo8dt5ee2em7cj2by3bx2bw1bw2bx7by2c
[32] http://njt.hu/njtonkorm.php?njtcp=eh7eg6ed1dr2eo9dt4ee5em0cj1bz2cf7ca4cc3bw4j
[33] http://njt.hu/njtonkorm.php?njtcp=eh7eg6ed5dr4eo7dt0ee3em2cj7by0cb9cb0bz9cd0bw1d
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[34] http://njt.hu/njtonkorm.php?njtcp=eh7eg2ed9dróeo7dt8ee5em0cj7bx8by9cd0cd5bz2ca5f
[35] http://njt.hu/njtonkorm.php?njtcp=eh0eg7ed8dr1eo8dt1eeóem7cjóby3caóce3bz2cd1by2h
[36] http://njt.hu/njtonkorm.php?njtcp=eh4eg7ed2dr3eo4dt5ee6em5cj6bx9by8bx9bz0cd7bx4l
[37] http://njt.hu/njtonkorm.php?njtcp=eh5eg4ed7dr8eo1dt6ee7em8cj7bx2bw7bx2ca1cc0cc1o
[38] http://njt.hu/njtonkorm.php?njtcp=eh3eg8ed5dr4eo1dt0ee3em8cj5cf2cb3by4cb1f
[39] http://njt.hu/njtonkorm.php?njtcp=eh2eg5ed8dr9eo2dt1ee6em7cj2by5by2by1cd8ca7cf8h
[40] http://njt.hu/njtonkorm.php?njtcp=eh5egóed5dr0eo5dt8ee5em0cj1by8by5cf0bw1by6cc3c
[41] http://njt.hu/njtonkorm.php?njtcp=eh3eg2ed3dr4eo9dt0ee1em6cj7cb0cd7cf0bx1cf2e
[42] http://njt.hu/njtonkorm.php?njtcp=eh2eg7ed8dr3eo2dt9ee4em3cj8bz3cb2by5ce2bx1g
[43] http://njt.hu/njtonkorm.php?njtcp=eh8eg7ed2dr9eo2dt9ee0em9cj8by1by2cc3bz0cc1bw8p
[44] http://njt.hu/njtonkorm.php?njtcp=eh0eg9ed2dr3eo0dt3ee8em7cj6by7by2bz5bw8cc5cc6p
[45] http://njt.hu/njtonkorm.php?njtcp=eh6eg5edódr1eo2dt9ee8em3cj8by9cb4bz3cf0ca3by8g
[46] http://njt.hu/njtonkorm.php?njtcp=eh5eg2ed7dr8eo5dt6ee3em4cj9cd0by7cc8bz7bz8i
[47] http://njt.hu/njtonkorm.php?njtcp=eh0eg7ed8dr1eo8dt1ee6em7cj6by3ca6ce3bz2cd1by2h
[48] http://njt.hu/njtonkorm.php?njtcp=eh8eg5ed0dr7eo4dt1ee0em3cj6by7bx4by3by6cf3bw0m
[49] http://njt.hu/njtonkorm.php?njtcp=eh5eg2ed9dr4eo3dt6ee7em2cj3cd2cd9cb6ce7ce0i
[50] http://njt.hu/njtonkorm.php?njtcp=eh5eg4ed5dr2eo9dt6ee1em0cj5by6by3cf6cd9cb2cb5l
Lábjegyzetek:
[1] The Author is doctoral student, Doctoral School of the Faculty of Law at the University of Pécs.
Visszaugrás
