December 13, 2023
We, former and current members of the judiciary, lawyers, academics and members of other legal professions,
recall our Appeal against the violation of the rule of law published in
January 2021, warning, among other things, of the massive violation of the rights of the accused in criminal proceedings and warning against the abuse of criminal proceedings for political purposes. This Call was a significant public criticism of the situation in the Slovak Republic and was supported by over four hundred Slovak lawyers (including 233 attorneys and 123 judges and judges emeritus). According to the Call, the change in the functioning of the judiciary and law enforcement agencies, in particular their efforts to gain popularity with the public, was a cause for concern. As signatories of the Call, aware of the long-standing problems in the courts, the prosecutor’s office, and the police, we pointed out that the answer must not be a populist attempt to make crime fighting illegal. The rule of law and the applicable law must be respected, even when they lead to fewer prosecutions and subsequent convictions in criminal proceedings or to fewer people being taken into custody. Furthermore, we have criticised the abuse of the institution of detention to put pressure on the accused in order to obtain his confession or cooperation in the detection of other criminal activities. We were also concerned about the use of the
testimony of a cooperating witness as key evidence in criminal
proceedings against judges or police officials, who were allowed to
enjoy their freedom in exchange for testifying against specific
individuals. We have pointed to the overuse of the above-mentioned
institute without rigorous scrutiny of the testimony of such persons,
allowing them to take disproportionate advantage, noting that such
testimony, when it is the only direct evidence against the accused, was found by the European Court of Human Rights (ECtHR) in the case of Adamčo v. Slovakia to be incompatible with the right to a fair trial. We have criticised the massive violation of the principle of presumption of innocence by politicians as well as the media, without any expected consequences. By violating the principle of the presumption of innocence, the government has tried to appear to be prosecuting
criminals, thereby creating a very dangerous atmosphere of hatred in
society. We also considered the relationship between law enforcement and the media to be a major problem. In our opinion, there was a systematic, long-term and selected media leaking information from the files, which then presented their biased and subjective view, and we criticised the fact that the state authorities did not react to these media excesses and did not stop the leaks. We criticized the publication of the minutes of the accused from the pre-trial proceedings in their entirety, which have the potential, as serious procedural errors, to jeopardize the legality of such criminal proceedings and, as a consequence, the very decision-making on the guilt or innocence of the prosecuted persons. At the time, the cooperation between law enforcement authorities and the
media was systematic. Media interest was used to discredit specific
persons. We have pointed out that in many cases it was not necessary to send a special commando to detain public officials who had previously avoided cooperation with law enforcement authorities and had been questioned only as witnesses, and to humiliate them with handcuffs with the active participation of journalists.
1. Slovak Bar Association surveys on the legality of the procedures of
the LEAs
We would also like to remind you that subsequently, on 1 April 2021, the Slovak Bar Association („SAK“) carried out the first internal survey
concerning the legality of the procedures of the Law Enforcement
Authorities („LEAs“). The intention was to compile a knowledge index
that would provide the SAK Bureau with information on the experiences of defence lawyers and the practices of law enforcement authorities in light of the growing concern of the professional public regarding the practice of the LEAs in relation to the execution of detention. 71 advocates responded to the survey. 72% of the respondents (51 respondents) indicated that in their experience, unlawful coercion is part of the practice of the LEAs. The remaining 20 respondents (28% of respondents) indicated that they had not encountered unlawful coercion in their practice. The next question sought to find out at which stage of the proceedings practices related to unlawful coercion are most common, according to the respondents‘ experience or information. As many as 98% of the responses confirm the existence of unlawful coercion in pre-trial proceedings (in terms of 31.4% of the responses this is a_modus operandi_, 39.2% of the responses speak of frequent existence and
27.5% of the responses speak of occasional occurrences). Up to 100% of the answers confirm the existence of unlawful coercion in pre-trial proceedings (in terms of 19.6% of the answers it is a _modus operandi_,52.9% of the answers speak of frequent existence), the remaining answers speak of occasional cases (27.5%). As many as 84.4% of responses confirm the existence of unlawful coercion at the post-indictment stage, although the vast majority of responses speak of occasional cases – 70.6% (in 2% of the respondents‘ opinion, it is a _modus operandi_, in 11.8% it is a frequent case). The majority of the answers, 56.9%, confirm the existence of unlawful coercion also in the time after the first instance decision, but only 2% of the respondents mention it as a frequent practice, 54.9% mention it as occasional cases, and in 43.1% of the answers, according to the respondents, there is no unlawful coercion at this stage. When asked whether the failure to file a custody petition in the case of an accused was conditioned or stimulated by his confession, 45 respondents (63%) indicated that their client had such an
experience. In the next question, respondents specified at which stage of the proceedings a motion for custody was most often conditioned.
Respondents confirmed that they had encountered this practice. In
pre-trial proceedings, 91.1% of responses confirmed it (according to
11.1% of responses it is a _modus operandi_, 46.7% of responses speak of common practice, 33.3% of responses speak of occasional cases); in pre-trial proceedings, 95.6% of responses (according to 13.3% of responses it is a _modus operandi_, 46.7% of responses speak of common practice, 35.6% of responses speak of occasional cases); after indictment 69.5% of responses (16.7% of responses speak of common practice, 52.8% of occasional cases); and after first instance decision 28.9% of responses (8.3% of responses speak of common practice, 22.2% of occasional cases). 54% of respondents answered (38 persons) that they are aware that after charges are filed against their client, witnesses are approached by other LEAs before they are questioned by the procedural investigator.
A second internal survey regarding the legality of the practices of the
LEAs was conducted by the Slovak Bar Association on 4 September 2023. 110 attorneys participated in the survey. 64% of the respondents (70 respondents) indicated that in their experience illegal coercion is part of the practice of the LEAs. The remaining 40 respondents (36% of respondents) indicated that they had not encountered unlawful coercion in their practice. In response to the next question, at which stage of the proceedings are the practices associated with unlawful coercion, according to the experience or information of the respondents, as many as 98.6% of the answers confirm the existence of unlawful coercion in the pre-trial proceedings (in terms of 14.3% of the answers it is a_modus operandi_, 48.6% of the answers speak of its frequent existence
and 35.7% of the answers speak of its occasional existence). Up to 98.6% of the answers confirm the existence of unlawful coercion in the pre-trial proceedings (in terms of 11.4% of the answers it is a modus operandi, 50% of the answers speak of frequent existence), the remaining answers speak of occasional cases (37.1%); 64.3% of answers confirm the existence of unlawful coercion at the post-indictment stage, although the vast majority of answers speak of occasional cases – 54.3% (in 1.4% according to the respondents it is a modus operandi, in 8.6% it is a frequent case); and the majority of answers do not confirm the existence of unlawful coercion at the time after the first instance decision (65.7% say it does not exist); according to 34.3%, there is sometimes unlawful coercion at this stage. 44% of the respondents (48 persons) said that they are aware that after charges are brought against their client, witnesses are approached by other LEAs before they are questioned by the procedural investigator.
2. Politicization of the Special Prosecutor´s Office by a purposeful
change in the law
We recall that the situation we criticized became even more acute after the election of the politician Daniel Lipšic as Special Prosecutor,
under whose leadership the Special Prosecutor´s Office began to engage in public commentary on selected „live“ criminal cases, thus
systematically violating the presumption of innocence. Through media statements, the Special Prosecutor´s Office also defended some National Criminal Agency („NAKA“) investigators who were facing criminal allegations. These suspicions were investigated by the Inspection Service Office, which is responsible for inspecting police officers, including those at NAKA. Other institutions also entered into these open conflicts between NAKA and the Office of the Inspection Service, in particular the Slovak Information Service („SIS“), the General Prosecutor’s Office, the Office of the Inspection Service and the Regional Prosecutor’s Office, and, of course, politicians. The network of conflicts between these institutions reached such proportions between autumn 2020 and autumn 2021 that journalists began to speak openly of a so-called ‚war in the police‘. The man who started it is the former head of NAKA’s operational department, Ján Kaľavský, who came to the Inspection Service Office with the claim that police officers manipulate investigations into major corruption cases. In order to obtain evidence, he became an agent providing, for example, wiretaps on the goings-on at NAKA. He was subsequently accused of corruption by his colleagues, and in August 2021 Káľavský fled across the border. He was caught in Bosnia and Herzegovina, but the courts refused to extradite him to Slovakia. He applied for asylum in that country. Subsequently, in an interview published on 6 September 2022 for the weekly Plus7dní, he stated that he feared for his life and published shocking information about how some NAKA officers had mentally abused, tortured, blackmailed,
fabricated evidence, falsified official records, detained them in the
early hours of the morning by a special commando and deliberately
mistreated them during arrest and detention in order to force them to make certain statements. Káľavský realised that he wanted no part in this when the investigator Čurilla told him, in connection with his
later accused colleague Kučerko, that he would soon be able to go to his home and might shoot his children, and when the general in custody, General Lučanský, died and these colleagues were rejoicing.
Káľavský considers his accusation to be fabricated, saying that the
legal wiretaps of the Čurilla show that he „_needed to attribute
anything to him. Anything!_“. He criticizes that Danilel Lipšic called
it informal debates of policemen.
We recall that in the past, only a prosecutor with 10 years of
experience, working at the General Prosecutor’s Office, could be elected as a special prosecutor. In 2020, the legislation was purposely changed so that someone who had no experience in the prosecutor’s office could be elected as a special prosecutor, and the special prosecutor subsequently became the politician Daniel Lipšic.
3. Reaction of the ECtHR to the failures of the Slovak Republic
The fact that our criticism contained in the Call from 2021 was
justified and that the results of the above-mentioned SAK surveys are an important indicator of human rights violations in criminal cases is evidenced by the reaction of the Constitutional Court of the Slovak Republic as well as the European Court of Human Rights (ECtHR) contained in its subsequent judgments as well as in the complaints communicated to the Government of the Slovak Republic.
3.1 Cooperating witnesses
As an example, we refer to the case of Erik Adamčo v. Slovakia of 1
June 2023, in which the ECtHR held that the Slovak courts had not paid any clear individual attention to the extent and nature of the benefits of cooperating witnesses obtained in exchange for incriminating evidence, despite the specific arguments made by the complainant Adamčo on this point. These benefits were significant, including the fact that the authorities delayed the prosecution of witnesses for multiple murders. The ECtHR noted that Slovak law did not appear to contain provisions relating to the granting of immunity and that such agreements were made outside judicial review. The applicant Adamčo received only abstract answers to his arguments in this respect. As the use of evidence in the trial concerning the applicant Adamčo with evidence from cooperating witnesses did not have adequate safeguards to ensure his fairness, it did not satisfy the safeguards of Article 6 and
therefore there had been a violation of the Convention for the
Protection of Human Rights and Fundamental Freedoms (the Convention).
In Vasaráb and Paulus v. Slovakia, 15.12.2022, the ECtHR concluded
that, given the way in which the domestic courts had responded to the applicants‘ request to question witnesses in their favour, the
proceedings as a whole had been unfair and there had been a violation of Article 6(1) and (3)(d) of the Convention. It noted that the applicants‘ proposed evidence should have related to motive as a structural element of the offence (motive was part of the offence) and the credibility of the evidence of the key witness against the applicants. They were therefore considered by the ECtHR to be relevant to the substance of the charges. In this judgment, the ECtHR reminded the Slovak authorities of the fundamental principle of criminal procedure, also contained in our Criminal Procedure Code, according to which the law enforcement authorities must clarify with equal diligence the circumstances testifying against the accused as well as those testifying in his favour. In the applicants‘ case, according to the ECtHR, the Slovak authorities failed to do so. The ECtHR stressed that they had examined only one version of events and had actively refused to examine the version put forward by the complainants. The ECtHR also stressed the need for careful scrutiny of the testimony of witnesses who are themselves implicated in criminal activity and testify in exchange for impunity or other benefits.
3.2 Ill-treatment in detention and disproportionate police intervention
With regard to the content of the Call from 2021, we further note that the ECtHR has notified the Government of the Slovak Republic of the complaint of Attorney Ribár, raising the question under Article 3 of the Convention whether the conditions of his detention constituted inhuman and degrading treatment. Further, whether there had been a violation of the applicant’s right to respect for his right to private and family life in view of the restrictions imposed on the applicant as regards his ability to call and see members of his family. The ECtHR also asks whether he has been discriminated against in the enjoyment of his rights under the Convention. Another complaint already communicated to the Government to the ECtHR concerns the allegedly disproportionate force used against the applicant during the police intervention at her family home to arrest her father. During the police intervention, the applicant, Ms Brhlová, sustained injuries which required her to be treated in hospital. The complainant’s criminal complaint in connection with the incident was successively dismissed by the police and the prosecutor’s office, which concluded that there was no evidence that a criminal offence had been committed. According to the complainant, the State failed to conduct an effective investigation into the illegal entry into her family home. The ECtHR asks the Government not only whether there has been an unjustified interference with the applicant’s
right to respect for her private life and home, but also, under Article
8 of the Convention, whether the proceedings concerning the applicant’s criminal complaint complied with the requirements of Article 8 of the Convention.
3.3 Article 18 of the Convention and the alleged ancillary purposes of
the interference with human rights
This year the ECtHR also notified the Government of the complaints of Jaroslav Haščák joined in one proceeding and of Róbert Fico. In both cases, the ECtHR is also asking about possible violations of Article 18 of the Convention by the Slovak Republic. Both of the above-mentioned complaints have their origins in criminal proceedings in connection with which the complainants allege violations of Articles 8 (right to respect for private life), 13 (right to an effective remedy), and 18 of the Convention (prohibition on the use of restrictions on the exercise of rights for a purpose other than that for which they were intended). In the case of Róbert Fico, it is also a violation of Article 6 of the Convention (the right to a fair trial) in relation to the proceedings on his constitutional complaint before the Constitutional Court of the Slovak Republic. The first complaint relates to the alleged leak of information to the press concerning the detention of the complainant Jaroslav Haščák and the search of his offices, which took place on 1 December 2020 in connection with criminal proceedings against him. On that date, a large number of police officers in heavy weapons entered the complainant’s business premises in order to carry out a search and detain him. Those acts were carried out under the scrutiny of the media.
The applicant submits that this exposure was tainted by the arbitrary
leaking of information about his arrest and the execution of the
searches to the media and that he was denied protection of his rights in this respect by the Constitutional Court. The ECtHR questions the Government of the Slovak Republic on the possible violation of the applicant’s right to the protection of his private life under Article 8 of the Convention, as well as on the violation of the right to an effective domestic remedy in respect of Article 8 of the Convention, as required by Article 13 of the Convention. The final question concerns whether, in the case of a leak for which the Slovak Republic was responsible, the restrictions imposed on the applicant’s right to respect for private life under Article 8 of the Convention were used for a purpose other than that envisaged by that provision, in breach of Article 18 of the Convention. The second complaint, which raises the question of a possible violation of Article 18 of the Convention, concerns the making of audio-visual recordings of the complainant Róbert Fico’s private meetings at a hunting lodge in criminal proceedings. Also in this case, the ECtHR asks about a possible violation of Articles 8 and 13 of the Convention in connection with the making of audio-visual recordings in the interior of the (hunting) lodge. At the same time, however, it raises the question of a possible violation of Article 18 of the Convention on the ground of whether the interference with the applicant’s right to privacy was aimed at a hidden purpose (political discrediting of the applicant) and not at the officially presented reasons for the criminal investigation. The purpose of Article 18 of the Convention is to prevent the abuse of power by State authorities. In the past, the ECtHR has found violations of Article 18 of the Convention, in particular in relation to states such as Russia, Ukraine, Azerbaijan, Georgia or Turkey. In relation to the Slovak Republic, no violation of this article has been found so far. If this international judicial body finds that Article 18 of the Convention has been violated, it will mean nothing other than that the responsible authorities have deviated from the basic principles and deliberately abused the criminal justice system.
4. Position on the Government’s current legislative initiative
In light of the above, we note with concern how the representatives of the opposition, many of whom have in the past been fully responsible for the violations of the fundamental principles of the rule of law that we outlined in the 2021 Call, are currently rejecting the necessary legislative changes in response to the decision-making of the highest judicial authorities, including the ECtHR.
With regard to the proposed changes to the Whistleblower Protection Act, we recall that under the ECtHR’s consistent jurisprudence, if a person has a defensible claim that he or she has been subjected to treatment by the police or other comparable state authorities, which is unlawful and contrary to Article 2 of the Convention protecting the right to life, Article 3 of the Convention prohibiting torture inhuman and degrading treatment or Article 8 of the Convention prohibiting unreasonable interference with physical and mental integrity or privacy, then these provisions imply a requirement to conduct an effective official investigation. This investigation must lead to the identification and punishment of those responsible. If this were not the case, then, according to this international judicial body, it would be possible in some cases for public officials to trample on the rights of those subject to their jurisdiction with near impunity. According to the ECtHR, the main purpose of an investigation is to ensure that public servants or public authorities are held accountable for treatment contrary to the above-mentioned articles of the Convention which has occurred in the course of their duties. In order for an investigation to be considered effective, the institutions and persons responsible for it must be independent of those being investigated. Thus, the investigation
of criminal activities by members of the Slovak Police Force must
clearly meet the requirement of independence, whereby not only
hierarchical, institutional independence is important, but also the
practical independence of the investigator. The current legal situation results in an interpretation of the law which, in its consequences, allows officers of the Slovak Police Force accused of criminal activities investigated by the Inspection Service Office to continue to work at the Inspection Service Office, which is in absolute contradiction with the aforementioned ECtHR case law concerning the independence of investigations. In view of the situation, an immediate state response is needed, and for this reason, too, an abbreviated legislative procedure is justified. This is to prevent the investigation of crimes committed by members of the Slovak Police Force from being frustrated. The situation arising in Slovakia is all the more serious because, according to the allegation of the former head of the NAKA’s operational department, Ján Káľavský, published on 6 September 2022 for the weekly Plus7dní, those who benefit from the current wording of the law and have recently been granted the status of protected whistleblowers have had the people under their authority psychologically abused, tortured, blackmailed, and fabricated evidence. The persistence
of these problems may lead to a threat to the fulfilment of the positive obligations of public authorities, as they arise from the case law of the ECtHR: the substantive positive obligations to take appropriate measures to protect life, physical and bodily integrity or privacy from unlawful and arbitrary interference specifically by public authorities, and, in the event of a breach of these substantive obligations, the positive procedural obligations to carry out an effective independent investigation of the events in question. In the context of the Police Force of the Slovak Republic, this may be a threat to its obligation to fulfill its statutory tasks, which include the protection of fundamental rights and freedoms, in particular the protection of life, health, personal liberty and security of persons and the protection of property, the detection of crimes and the identification of their perpetrators, or the conduct of investigations into criminal offences.
With regard to changes to the Criminal Code and the Code of Criminal Procedure, we recall the relevant parts of the report of the European Committee for the Prevention of Torture and Inhuman or Degrading Treatment or Punishment (CPT) on the visit to Slovakia, which took place from 19 to 28 March 2018, according to which the CPT’s top priority should be to ensure that deprivation of liberty is ordered only as a real last resort at each stage of the criminal justice system, from the preparatory proceedings to the execution of sentences. The CPT urged the Slovak authorities to continue their efforts to reduce the prison population in a sustainable manner, in line with the relevant recommendations of the Committee of Ministers of the Council of Europe.
In this respect, the CPT referred in particular to Recommendations
R(99)22 on prison overcrowding and prison population growth, Rec(2014)4 on electronic monitoring, Rec(2017)3 on European rules on sanctions and Community measures, Rec(2018)5 on children with incarcerated parents, Rec(2003)22 on parole, Rec(2006)13 on the use of pre-trial detention, the conditions under which it is carried out and the provision of safeguards against abuse, Rec(2008)11 on European rules for young offenders subject to sanctions and measures, and Recommendation Rec(2010)1 on probation rules of the Council of Europe. As regards Recommendation R(99)22 on prison overcrowding and prison population growth, the annex to it defines the basic principles. According to the first, of these, deprivation of liberty should be considered as a last resort and only ordered when any other sanctions or measures are manifestly inadequate in view of the seriousness of the offence.
According to the fourth, States should consider the possibility of
decriminalising certain types of offences or reclassifying them so that
they are not subject to custodial sentences. Regarding Recommendation Rec(2014)4 on electronic monitoring, the Committee of Ministers of the RE recommended that the governments of the RE Member States, when reviewing their respective legislation and practice, take all appropriate measures to apply the principles on electronic monitoring set out in the Annex to this Recommendation. In the introduction to this Recommendation, the RE Committee of Ministers agreed, inter alia, that deprivation of liberty should be used as a last resort and that most suspects and offenders can be dealt with effectively and cost-effectively within the community. It further stated that the continued growth of the prison population may lead to conditions of deprivation of liberty that are not in conformity with Article 3 of the Convention, as highlighted by the relevant case-law of the ECtHR. It reiterated that prison overcrowding and the growth of the prison population are major challenges for prison administrations and the criminal justice system as a whole, both in terms of human rights and the effective management of prison institutions, and acknowledged that
electronic monitoring used in the criminal justice process can help to
curb the resort to deprivation of liberty, while ensuring effective
supervision of suspects and offenders in the community, and thus helping to prevent crime.
In light of the situation described above, we also support the abolition of the Special Prosecutor´ Office, noting also that the misconduct affecting fundamental human rights and freedoms identified by the highest judicial authorities has occurred in many cases in the exercise of its jurisdiction.
In conclusion, once again, as in the first Call of 2021, we state that
we consider it dangerous if the violation of the rule of law in Slovakia
and the prevention of necessary legislative changes is justified by the
opposition and some NGOs by inadequate reference to European values. In our view, it is of the utmost importance that the relevant institutions of the European Union and the Council of Europe distance themselves from the actions of the Slovak opposition if they are not in line with the rule of law. We will keep these international institutions informed about the situation in Slovakia.
Call signers :
1. JUDr. Milan Ľalík – Judge Emeritus, former Deputy President of
the Constitutional Court of the Slovak Republic
2. Dr.h.c.prof. JUDr. Jaroslav Ivor, DrSc.
3. Dr.h.c.prof. JUDr. Lucia Kurilovská, PhD.
4. Assoc. JUDr. Branislav Fábry PhD.- university lecturer
5. JUDr. Marica Pirošíková, PhD.- attorney at law, advisor to the
Minister of Justice of the Slovak Republic
6. JUDr. Tomáš Suchý, PhD.- lawyer and university lecturer
7. JUDr. Martin Píry, PhD.- university lecturer
8. JUDr. Štefan Harabin, Judge of the Supreme Administrative Court of the Slovak Republic, two-time Chairman of the SR Judicial Council and the NSSR, Deputy Prime Minister of the Slovak Republic for Legislation and former Minister of Justice of the Slovak Republic
9. JUDr. Eva Bieliková- Judge
10. JUDr. Ing. Gréta Noé, LLM, PhD.- Associate
11. JUDr. Štefan Neszméry- attorney at law
12. JUDr. Zuzana Štrbáková- attorney at law
13. JUDr. Martin Ribár- attorney at law
14. JUDr. Marián Bošanský – attorney at law
15. JUDr. Lucia Matejová – attorney at law
16. Mgr. Judita Laššáková
17. JUDr. Katarína Rusnáková- judge emeritus
18. JUDr. Danica Rusnák Borisová- advocate
19. JUDr. Miroslav Zobok- attorney at law
20. JUDr. Andrej Gara- attorney at law
21. Mgr. Eva Garová- attorney at law
22. JUDr. Ing. Ľubomír Havlík- attorney at law
23. Doc. JUDr. Adrián Vaško, PhD.- university lecturer
24. JUDr. Dagmar Buchalová – Judge
25. JUDr. Martin Pohovej- attorney at law
26. JUDr. Marta Jasíková- attorney at law
27. JUDr. Loránt Kósa- attorney-at-law
28. JUDr. Katarína Roskoványi- Prosecutor of the GP SR
29. JUDr. Jaroslav Kozolka – Prosecutor of the GP SR
30. JUDr. Roman Benedikovič – Judge Emeritus
31. JUDr. Peter Rajňák- Judge
32. JUDr. Daniela Ellen Rajňáková- Judge
33. Mgr. Filip Gašparec- attorney at law
34. JUDr. Jaroslav Klátik- attorney at law
35. JUDr. Bohumil Novák- attorney at law
36. JUDr. Zita Leimbergerová- judge
37. JUDr. Michal Mandzák- attorney at law
38. JUDr. Ľubomír Lipovský- attorney at law
39. Mgr. Filip Ľupták – VSÚ
40. JUDr. Vladimír Mitro- attorney at law
41. PhDr. JUDr. Igor Kleniar, PhD.
42. Mgr. Igor Cibula- attorney at law
43. JUDr. Roman Balco – attorney at law
44. JUDr. Peter Filip- attorney at law
45. JUDr. Peter Erdős – attorney at law
46. JUDr. Dušan Ivan- attorney at law
47. JUDr. Bernard Pekár- attorney at law
48. Mgr. Jaroslav Polko
49. Mgr. Elena Szabóová- attorney at law
50. JUDr. Jakub Križan- attorney at law
51. JUDr. Marcela Morsztýnová- attorney at law
52. JUDr. Erik Magál- attorney at law
53. JUDr. Tatiana Biedniková- judge emeritus
54. JUDr. Helena Nagyová
55. Mgr. Adriana Lichnerová
56. Mgr. Viera Hradiská
57. Mgr. Jakub Môcik- trainee attorney at law
58. JUDr. Viera Vadovická – attorney at law
59. JUDr. Ľubomír Urmanič
60. Mgr. Simona Uhrinová, MBA, LL.M- attorney at law
61. JUDr. Alena Gajdošová
62. JUDr. Helena Kožíková – judge emeritus
63. JUDr. Jana Tamášiová
64. JUDr. Dušan Repák- attorney at law
65. JUDr. Martin Gajňák
66. JUDr. Ayše Pružinec Eren – Judge
67. Mgr. Dalibor Miľan – Judge
68. JUDr. Vladimír Šebo – lawyer
69. JUDr. Želmíra Šebová – judge emeritus
70. JUDr. Soňa Soboňová – lawyer
71. Mgr. Marián Michnica
72. Mgr. Dušan Oravec – attorney at law
73. JUDr. Róbert Baran
74. JUDr. Martin Žuffa, PhD.
75. JUDr. Matej Bobovský
76. JUDr. Erik Schmidt – attorney at law
77. JUDr. Eva Goconová – attorney at law
78. Mgr. Zuzana Zajíčková – attorney at law
79. JUDr. Ľubomír Bušík, PhD. – judge
80. JUDr. Stanislav Ďuríček
81. JUDr. Peter Gdovin – attorney at law
82. Viera Vadovická – lawyer
83. JUDr. Tatiana Biedniková – judge
84. JUDr. Viliam Košút
85. JUDr. Helena Loduhová – judge emeritus
86. Mgr. František Peniaško – attorney at law
87. JUDr. Ľubomír Krajny
88. JUDr. Daniela Konečná – attorney-at-law emeritus
89. JUDr. Peter Krivák – attorney at law
90. JUDr. Adriana Soldán Steinerová
91. JUDr. Iveta Bžánová – notary
92. JUDr. Peter Oreško – lawyer
93. Mgr. Martin Škuba – attorney at law
94. JUDr. Valéria Haščáková – attorney at law
95. JUDr. Ján Jamrich – judge
96. JUDr. Jozef Onďák – lawyer
97. JUDr. František Polák – attorney at law
98. JUDr. Ivan Hubka – attorney at law
99. JUDr. Milan Križalkovič – attorney at law
100. JUDr. Petra Hatalová – attorney at law
101. JUDr. Katarína Rosinová – advocate
102. JUDr. Janka Fabriciová
103. JUDr. Ingrid Šamajová
104. JUDr. Michal Irsák – notary emeritus – attorney at law
105. Mgr. Ivan Antal – Judge
106. JUDr. Milan Mitterpák – judge
107. JUDr. Michaela Wewberová – attorney at law
108. JUDr. Blaťena Rusnáková – Prosecutor Emeritus
109. JUDr. Vojtech Főldes – attorney at law
110. Mgr. Viera Főldesová – lawyer
111. JUDr. Michaela Ševčíková
112. Mgr. Roman Toman, PhD. – attorney at law
113. Mgr. Peter Ivor – attorney at law
114. JUDr. Mária Tvrdíková – judge
115. JUDr. Vladimír Zimányi – judge
116. Mult. Dr. h. c. prof. JUDr. Mojmír Mamojka, CSc. – Dean of the
Faculty of Arts in Bratislava, Dean of the Faculty of Arts of the UMB B. Bystrica, Chairman of the Constitutional Law Committee of the National Assembly of the Slovak Republic, Judge Emeritus of the
Constitutional Court
117. JUDr. Peter Púchovský – attorney at law
118. Mgr. Miroslav Ľuba
119. JUDr. Miroslav Mikuš – attorney at law
120. JUDr. Michal Švec – attorney at law
121. JUDr. Miroslava Petrovičová, LL.M. – attorney at law
122. JUDr. Matej Kán – attorney at law
123. JUDr. Radoslav Hajdúch, LL.M. – attorney at law
124. JUDr. Dušan Ďurík – attorney at law
125. JUDr. Radoslav Kačur – attorney at law
126. JUDr. Daniela Bergerová – Judge
127. JUDr. Martin Janáč – advocate
128. JUDr. Gabriela Šimonová – Judge
129. Mgr. Ianko Trojak – attorney at law
130. JUDr. Mgr. Jozef Šimon, CSc.
131. JUDr. Ján Kubiš – attorney at law
132. JUDr. Stanislava Bezáková – Judge Emeritus
133. JUDr. Pavol Špaček – attorney at law
134. JUDr. Ladislav Tichý
135. JUDr. Igor Burger – judge
136. JUDr. Milam Valašik – lawyer
137. Mgr. Katarína Pjatáková
138. JUDr. Dávid Matyšák, EMBA, LL.M. – attorney at law
139. Mgr. Jana Pašková – attorney at law
140. JUDr. Katarína Ondrejáková – judge
141. JUDr. Jarmila Maximová – judge emeritus
142. JUDr. Monika Nádaská – attorney at law
143. JUDr. Andrej Liga
144. JUDr. Tomáš Nemček – attorney at law
145. JUDr. Bianka Gelačíková – judge
146. JUDr. Róbert Jano – attorney at law
147. JUDr. Viktor Križiak – attorney at law
148. JUDr. Ladislav Janči – attorney at law
149. JUDr. Milan Ščigulinsky
150. JUDr. Juraj Almasi
151. Roman Kolev
152. JUDr. Milan Rojček
153. JUDr. Ildokó Osvaldová
154. JUDr. Eva Železníková
155. JUDr. Ladislav Gál
156. JUDr. Jozef Tarabčák
157. JUDr. Alexander Filo
158. JUDr. Oľga Nižňaská – judge
159. JUDr. Lukáš Machala
160. JUDr. Ing. Michal Ševčík, PhD.
161. JUDr. Patrícia Krásna, PhD., LL.M.
162. Mgr. Jaroslav Polko
163. JUDr. Ladislav Kopál
Links:
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[1] https://pravnystat.eu/en/
Slovenčina 
English