Transcript Judicial Training and research on EU crimes against environment and maritime pollution Entela Cukani 26/29 June - Dipartimento di Scienze Giuridiche Unisalento Room R 24

Judicial Training and research on EU crimes against
environment and maritime pollution
Entela Cukani
26/29 June - Dipartimento di Scienze Giuridiche
Unisalento
Room R 24
Environmental Crimes: Marine Pollution –
Situation and Legislation Applicable in Albania
Entela Cukani
General overview
Albania with its 28,748 km2 is one of the
smallest countries in Europe situated on the
Western edge of the Balkan Peninsula.
The coastal exclusive economic zone covers
about 12,000 km. It can be divided into two
different areas:
 the northern - Adriatic coast considered
the accumulation marine area, generally a
sandy one, with a total length of about 259
km crossed by nine rivers;
 southern - Ionian coast
which runs
southeast about 170 km from Cape
Karaburuni to Stillo Island on Greek
border, this coastal zone is mainly rocky;
General overview
 Albanian coastal zone is the area where social-economic development in
the past and nowadays, has been more intensive than in the rest of the
country
 during the ’90, most of Albanian industries, many of them in the northern
part, were obliged to close down – migration of people from these zones
to the costal area
 Now days about 60% of the Albanian population is living in the coastal
areas
 diminishing of pollution as a result of the closure of the industries
 increase of urban pollution in the coastal area caused by the tourism
development and by the increasing number of inhabitants.
Main causes of environmental and marine pollution
 Uncontrolled migration of people – construction of thousands of
illegal constructions along the coastal zone not preceded or
accompanied by necessary infrastructure - tourist constructions
 The wastewater, are discharged untreated into the surface waters
and into the sea (Part of the cities and towns of Albania are not
connected to the sewage network and part of the existing network
is very old)
 Operational pollution from ship by illegal discharges of oil and oily
mixtures into the sea (ARMO case)
 Urban thrown into the rivers.
Environmental legal framework
 1998 (Constitution of the Republic of Albania)- some principles and
requirements for protection of environment such as the principle of
the sustainable development and the public right of environmental
information, became constitutional norms

Chapter IV – Economic, Social and Cultural Rights and Freedoms
 Article 56 “ Everyone has the right to be informed for the status of
the environment and its protection”

Chapter V—Social Objectives
 article 59 (points e-f) states the obligation of the state to provide
for a healthy and ecologically adequate environment for the
present and future generations, as well as the rational exploitation
of forests, waters, pastures and other natural resources, on the
basis of the principle of sustainable development.

(continue…….
Environmental legal framework
•
•











1993. First national Environmental Law “Law on Environmental Protection”
2002. New “Law on Environmental Protection”
The Law on Development of Tourism Priority Zones (1993),
The Law on Fishing and Fish Farming (1995),
The Law on Water Resources (1996),
The Law on the regulatory framework of the water supply sector and the treatment of the
polluted waters (1996),
The law on Environmental Impact Assessment EIA (2003)
The Law on Protected Areas (2002)
The Law on Protection of Marine Environment from pollution and damages (2002),
The law on Environmental Management of Wastewater (2003)
The law on Environmental Management of Solid Waste (2003)
Law No. 8053, dated 30.06.1999 on the right of information on official documents
Law No.8875, dated 04.04.2002 on Coastal Guard., which regulates the organization and
functioning of this important state structure in the protection of marine environment.
Albanian criminal code provisions
 Some of the environmental violations represent criminal acts under the Albanian
Criminal Code, Chapter IV (art 201 – 207) “Offences against the environment” and
are prosecuted under the general principles of the criminal legislation.
 Article 203 intitoled Water Pollution states
Pollution of the seas, rivers, lakes or network resources waste collection and distribution
of toxic, radioactive or other substances that disrupt the ecological balance, shall be
punished by imprisonment from one to five years.
The same act, when causing consequences for the health of people, is sentenced from
five to ten years.
State documents relevant for
environment
 National Water Strategy – Approved by the Albanian Council
of Ministers on 2004
 National Action Plan for Environment – Approved by the
Council of Ministers by the decision no. 34, dated
28.01.2002
 National Action Plan for Environment and Health -- Approved
by the Council of Ministers on 1999.
 Local Environmental Action Plans, LEAPs
State of Ratification of Convents
Convention/ protocol (relative to marine State of
ratification
and costal zones)
Year
Barcelona Convention for the marine
protected areas, 6 protocols
Ratified
2000
Ramsaar Coinventions
Ratified
1995
Aarhus Convention on Access to Information, Ratified
Public
Participation in Decision Making and Access
to Justice
2000
Espoo Convention on Transboundary Impacts
2004
Art 122 Constitution
Ratified
Legislative developments (to come into
force)
Some developments are made in horizontal legislation drafting new
laws which transposes the European directives:
 Law no. 10431, dated 9.6.2011 “On the environmental protection”,
 Law no. 10440, dated 7.7.2011 “On the environmental impact
assessment”,
 Law no. 10448, dated 14.7.2011 “On the environmental permitting”,
 Draft law “On the strategic environmental assessment (planned to be
approved)
 2012. In process the “Law on SEA”
New Strategic Documents
New strategic documents
 National Waste Management Plan 2015-2025
 National Waste Strategy
 National Cross-Sector Strategy of Water Supply and Sanitation Services
 Regional Waste Management Plans for the districts of Tirana and Elbasan.
 Management Plan of Butrinti National Park
 Management Plan of Managed Nature Reserve Kune-Vain-Tale
Law 10431, date 09.06.2011 “ On
Environmental Protection”
 Principal goal: prevention, control and reduce water pollution, air, soil and
pollution of any kind (art. 3);
 Definitions article 5
 "Environment" are natural components: air, land, water, climate, flora and
fauna in the totality of interactions with each other, as well as cultural
heritage, as part of the environment created by man.
 "Pollution" is the introduction of direct or indirect, as a result of human
activity, of substances, vibrations, radiation, unpleasant odors, heat or
noise into the air, water or land, to the extent that may be detrimental to
environmental quality or human health, which could lead to material
property damage or worse and interfere with other services to legitimate
uses of the environment.
Responsibility: the polluter pays principle 2002
and 2011 legislation
 Refers to the costs paid by the polluter for the improvement of the polluted
environment and its restoration to an acceptable state. This is reflected in
the costs of production, consumption of goods and services that cause
pollution and damages.
 The environmental regulatory authorities may: impose fines, confiscate
the equipment or the materials causing pollution or damaging the
environment; suspend or revoke the environmental permit, close the
activity.
 in case of administrative contraventions and/or criminal violations, there
shall also be evaluated the damages caused to the environment by the
infringing person who shall be liable for the payment of the sum.
Violation: penal / administrative ones

Violation (art 69)
1)
2)
Penal act
Environmental Inspectorate asks for penal proceding
Administrative violations(a.v)
Environmental Inspectorate set penalties,
sanctions may be taken into two calendar years from the date of decision of a.v .

In case of serious offenses of this law or if the person has not paid the penalty
imposed under this law, the inspectorate has the right to put the property under
sequestration

In case of fine not paid in time, the Ministry of Environment may suspend the
environment permit.

Entity to which the measure of suspension or revocation of the environment
permit has been imposed, has the right to appeal to the head of the responsible
structure as provided in specific legislation.
 .
Which law sanction maritime pollution?
Law No. 8905 – 06.06.2002 “On Protection of Marine from Pollution and
Damage” as amended in 2006
 Developed as an obligation for incorporating into the Albanian national
legislation requirements that come out of the Barcelona Convention and
its Protocols
 The aim of this law is the protection of the sea from pollution and
damages from human activities in the sea and the coastal area and
pollution and damage prevention as well
 The law specifies that the marine environment is integrated part of the
environment of the Republic of Albania. As such, it’s protection is subject
to all the environmental laws and bylaws of the Republic of Albania and
the international conventions, protocols, and agreements ratified by the
country.
Protection of marine environment
Especially obliged to protect the marine
environment and to implement the provisions
of this law are:

legal and physical entities, public or
private, national or foreign, that utilise the
marine environment or carry out their
activities in this environment;

every deployment on the sea coast;

every vessel deployed or sailing the sea;

aeronautical craft flying over the marine
environment

The protection of the marine from
pollution and damage is а duty of central
and local governmental structures, civic
оrgаnisаtiоns and citizens

The administration of the marine
environment is the responsibility of
governmental bodies entrusted by law

Control authority - exercised directly by
the Inspectorate of Protection of the
Еnviгоnment, bу portual authorities, and
other structures as defined by law.

The Inspectorate interacts with portual
authorities, the Fishing Inspectorate, the
State Роlicе and the Coast Guard of the
Republic of Albania (art.7).

The control operated by such
Inspectorate has to be continues and
permanent ( art.8)
Forbidden activities
The law prohibits activities listed
in article 6 .
But the same article specifies that
“Waste defined in Annex 2
attached to this Law may be
dumped into the sea only upon
authorization of the Ministry of
Environment”

Art. 6 Prohibit activities

the dumping of hazardous, poisonous and explosive
substances and waste;

the dumping of substances and solid matter;

the discharge of hydrocarbons and polluted waters;

the discharge of solid substances and material of any
kind and nature, with the exception of fishing vessels
and equipment and the materials and resources
needed for the construction of ports, pontines and other
structures, in accordance with blue prints approved by
the Ministry of the Environment and conditions set by
this Ministry;

the dumping of waste and all manner of substance from
the ships, platforms, installations and the coast;

the transportation of hazardous substance and waste;

the sinking of ships, cargoes and merchandise of all
type and manner;

the sinking and abandonment of any installation that
used to serve for various activities;

the construction and operation of equipment with
radioactive material;

the burning of substances and materials of any kind;

the entrance into ports with unclean vessels of any kind
Pollution
management –
Chapter IV
Sea platforms, ships of gross tonnage above
400 BRT, and any activity taking place in the
marine environment, are obliged:
 to carry waste collection containers in
accordance with the type and proportions
of the installation and activity;
 to use filters that separate water from used
hydrocarbons;
 to record in a diary book the operations
dedicated to collection and disposal of
waste;
 to create internal monitoring systems and
publicize the monitoring data
 The collection and disposal
of waste in the marine
environment by economic
and social activities and by
anchored or sailing ships is
subject to the provisions of
this law and the by-laws
ensuring its implementation
 Regulation governing the
management of waste in the
marine environment is
designed jointly by the
Minister of Environment, the
Minister of Transports &
Telecommunications and the
Minister of Territorial
Regulation and Toursim
Notification of pollution (article 13)
 Регsоns dеtесting pollution in the marine environment аrе obligated to
give рrореr notification to the port authority оr the closest gоvеrnmеntаl
authority.

Ship captains, platform operators оr persons of equal rаnk in аrmу
mаrinе environmеnt activity аrе obligated to notify port authorities
immediately upon detecting pollution caused by hydrocarbons оr
hazardous substances.
 Such notifications should include dates indicated in the same article.
 The Port Authority upon verification of the truthfulness of notification,
informs the Ministry of Transports and Telecommunications, the Ministry of
Environment and the local government in the territory of which the
pollution has taken place.
Elimination of pollution and sanctions
Pollution elimination
article 14

.The physical or legal entities
causing pollution to the marine
environment are obligated to clean
up the polluted zone and return it to
its previous condition.

They are obligated to indemnify
damages, as well.

In the first instance, the obligation
to take steps to eliminate the
pollution they may have caused falls
upon the captain of the ship, the
operator of the platform and persons
of equal rank in other activities
taking
place in
the
marine
environment
Forbidden activities
article 18

The Inspectorate for Protection of the Environment
is entitled to institute charges against subjects
involved in activities forbidden by Article 6 of this
Law if and when such activities qualify as criminal
offences.

2. In cases when violations qualify as
administrative infringements, the Environmental
Inspectorate authorises the immediate termination
of the activity and the confiscation of the craft and
equipment causing the pollution.

In case of small scale pollution as defined by
Article 2,are imposed fines from thousand to 500
thousand leks.
21
Law and practice (open discussion)
12 July 2011
A great quantity of “Solar” (around 1
ton), a fuel ingredient, was spilled in
the beach of Zvernec, near Vlore, by a
ship of the ARMO company causing a
great pollution of this coastline.
Any prosecution???
What about the elimination of the
pollution?
Polluter pay principle?
Which is the Ministry or State Organism dealing with
maritime crimes and
environmental crimes in general?

Ministry of Environment, Forests and Administration of Waters

National Environmental Agency, as the competent authority to determine the
conditions to be complied with for environmental permits. During the transition period (2
years from the entrance into force of the 2011 law) such Agency will operate under the supervision of the
Environment Ministry but the law is silent concerning more of the cooperation modalities.

Regional Environmental Agencies (REAs) -
Executive territorial agencies of the Ministry of
the Environment with the competence of giving the environmental permits, environmental inspection and
monitoring

Environmental Inspectorate, units responsible for the environmental issues near
the central and local authorities

Local Government Authorities

Public medias in realizing the public right to be informed on the state of the
environment
continue….

Role of the Environment Inspectorate

functions within the Ministry of Environment, as a specialized body on
environmental control.

composed by the Chief Inspectorate, inspectors of the Ministry of Environment
whom exercise their control activity in all the territory of the state and inspectors of
the REA-s that operate within the prefecture’s territory

exerts continuous control on the environment and the polluting activities; orders for
the implementation of obligatory measures to be taken for the improvement of the
state of the environment, for the mitigation of the pollution and the damage of the
environment; informs the local authorities on the state of environment; imposes
sanctions ect.

When the violation constitute a penal act, the Environmental Inspectorate asks for
penal proceeding.

When they constitute administrative contraventions penalties are set directly by the
Environmental Inspectorate.
Role of Local Government Authorities
Some of the duties


With 2003 law on the competencies of
local government, responsibility for urban
sewage and solid waste management,
(two of the main causes of environmental
pollution) goes from the Ministry of
Territory Adjustment and Tourism to the
Municipalities and Communes;
draft local plans for environmental
protection and territory adjustment;

inform the public on the state of the
environment and local activities that are
subject to the environmental impact
assessment

administer the urban wastes, the waste
water treatment and solid waste plans
Bad practices

Regional and Local Environmental
(Development) Strategies are rare
documents in the country (no examples
for marine zones);

Local authorities play no active role on
informing the public regarding different
aspects related to Hot spot presence,
impacts and potential interventions

Example : the zone of the
“Marine
School” in Vlora, has been linked like an
HotSpot for the high degree of pollution
as a result of the wastewater discharges
by the Ministry of
Environment,
underlining that “Bathing Must be Strictly
prohibit”. However, not a table or other
type of such communication is given to
the population, that continuous to use this
part of the coastal zone for bathing.
Control of sea
environment and sea
activity
The Coastal Guard of the Republic of
Albania (branch of the Navy) is established
for the purpose of enforcing the law of the sea.
a) To effectuate Marine Pollution Education,
Prevention, Response and Enforcement;
b) To enforce legislation with regard to
marine fishing;
c) To ensure recreational boating safety;
d) To enforce legislation with regard to living
marine and submarine resource protection,
including in the sea bed;
e) To enforce legislation on the archeological
and cultural values in the Albanian sea area
 ...in adittion is exercised directly
by:
 the Inspectorate of the Protection
of the Environment that interacts
with :
 Harbour Masters
 Fishing Inspectorate,
 State Police and the
 Coast Guard of Albania - As stated
by the Law No 8875 of 04.02.2002 the
Albania Costal Guard is the law
enforcement
body
that
include
pollution by ships.
Is under its
competencies
to
effectuate
the
monitoring and the detection of the
polluter. On the other hand this
institution
is
responsible
for
collecting
evidences
and
investigations. In such situations
prosecutors and magistrates are not
involved.
Weaknesses of the institutional framework
 Beside the good legislation and institutional framework the concrete
communication in regional and local level is considered very weak and not
concretely coordinated.
 There is a lack in communication between local institutions to setup a
regular monitoring procedure for the permits given to the business of
construction works.
 It is not harmonized cooperation between Inspectorate of Environment
and REAs, REAs with Local Government and other Regional and Local
Institutions
 the Ministry of Justice, magistrates and prosecutors are not sufficiently
involved in the matter of sanctioning illegal discharges (especially the
ones from the ships) – only few cases introduced to the courts
To whom and how report an environmental
crime? Who gather evidence for prosecution?
 1) Penal act: the Environmental Inspectorate asks for penal
proceeding.
 Within port jurisdiction
the Harbor Master have the
Within the territorial sea
Costal Guard Officers have the
enforcement power.
law enforcement power.
 Reports are transmitted to the public prosecutor who initiate
the proceeding.
 The competent court is the Judicial court of the place where
the offence occurred
 Open discussion on marine boundaries
 1970
 2001
 2009
 Constitutional Court decision (2011)
 Territorial and internal boundaries
…prosecution
2) Administrative contraventions: penalties are set directly by the Environmental
Inspectorate
 Against the decision for penalty, within 10 days from its notification, it is possible to
appeal at the Ministry of Environment who has to respond to the appellation within
15 days from its deposit.
Against such decision or to the non – response
within the deadline of 15 days, it is possible to propose an appeal at the Tirana
District Court
 not respect the measures and the sanctions decided by the Environmental
Inspectorate/same contravention committed in the same year
the Chief
Inspector or the Minister of Environment order the suspension or the permanent
closure of the activity
.
Against such decision it can be an appeal to the district court within 5 days from
the day of the receipt of the notification.
Specific case by case situation

persons detecting pollution in the marine environment
obligated to give proper notification to the port authority or the closest
governmental authority.
 Ship captains, platform operators or persons of equal rank in any marine
environment activity
obligated to notify port authorities immediately
upon detecting pollution caused by hydrocarbons or hazardous substances
Port Authority upon verification of the truthfulness of notification
.
Informs
the Ministry of Transports and Telecommunications, the Ministry of
Environment and local government in the territory of which the pollution has
taken place.
Other cases
 pollution caused by the military
the Inspectorate
of Environment notifies the Ministry of Defense
obligated to launch the necessary measures for cleaning
the polluted zone.
 pollution caused by foreign military ships
the
diplomatic channels
submit due notice to
responsible state with requirements for cleaning
pollution and indemnifying damages.
Norms criminalizing Illegal disposal of
hazardous waste in sea or rivers
 Albania prohibits the imports of hazardous wastes for storage, preservation
or disposal by virtue of Article 22 of the Environmental Protection Law
(8934/2002).
 Moreover, Article 6 of Law On Protection of Marine Environment from
pollution and damage among other forbidden activities lists :
 а) the dumping of hazardeous poisonous and explosive substances and
waste;
 с) the discharge of hydrocarbons and polluted waters;
 f) the tгаnsроrtаtiоn of hazardous substance and waste;

(continue….
Transportation of hazardous waste without the permission
of the receiving country
Germany to Albania
(Schmidt-Cretan case)
EU and World Bank
(project) to Albania -1992

Between 1991 and 1992, a German
company exported 480 tons of hazardous
wastes in five shipments as humanitarian
aid to Albania. The transfer was legal
under EC regulations in force at the time.
Return of the chemicals was requested
when the Albanian authorities discovered
the hazards involved, but their prior
consent provided a legal base for refusal .


The Basel Convention, the publicity by
Greenpeace, international pressure and
Albania’s inability to dispose safely of the
chemicals,
forced
the
German
government to accept the return of the
1991-92 shipments.
Under the EU's Poland-Hungary Aid for
the Reconstruction of the Economy
(PHARE) Program, 214 tons of pesticides
were transported to Albania. The World
Bank funded a similar project (Critical
Imports Project), which led to an
additional import of 160 tons of
pesticides. Reports published in 1993
indicated that Albania had already
possessed 3000 tons of pesticides stored
by the Communist government.

Furthermore,
CNN
reported
that
continued acceptance of hazardous
wastes seriously endangered Albania
industry and questioned whether it had
become ‘Europe’s dumping ground’ rather
than its ‘playground’.
Transport of hazardous waste: Basel Convention and
Albania

The Basel Convention on the Control of Trans-boundary Movements of Hazardous
Wastes and Their Disposal is an international treaty that was designed to reduce
the movements of hazardous waste between nations, and, specifically, to curb the
transfer of hazardous waste from developed to less developed countries.

Albania signed the convention on June 22, 1999

Article 13, paragraph 3, obliges signatory countries to annually submit information
on all trans-boundary movements of hazardous wastes or other forms of waste in
which they have been involved.

The reports must include the amount of wastes exported or imported, their
category, characteristics, destination, and the method of disposal.

Because of differences in national definitions of hazardous waste, waste
classifications, and different methods of data collection, not all movements of
hazardous wastes were being recorded by the signatory parties –( Nairoby 2006)

Annex I of the Basel convention classifies different type of waste in trans-boundary
shipments with a Y-code which are to be considered hazardous .
Transporte of hazardous waste: Basel Convention and
Albania

Data from the UN Commodity Trade Statistics Database indicate that between
2003 and 2010 large amounts of potentially hazardous waste – including chemical
substances – were exported from the EU to Albania. This is contrary to the fact that
the import of waste into Albania is highly restricted. Waste matter yet to be
imported requires a special permit from the cabinet and formal approval from the
Minister of the Environment. Despite this tightening of regulations, waste continues
to be dumped in Albania without the necessary permits.

Albania has been subject to the Basel Convention since 1999 and is thus obliged to
divulge information pertaining to all cross-border transport of hazardous waste
substances. Nevertheless, because of differences in national definitions of
hazardous waste, classification codes and differences in the manner of data
collection, it would appear that not all transports are recorded. Waste materials
transferred to Albania and registered in countries of departure is still not
accompanied by a convention secretariat report on import into Albania.
Hazard in France but
not Albania
For example, in 2004 France reported the dispatch of 588 tonnes of
waste that resulted from the treatment of metal surfaces, the
importation of which was never reported by the Albanian authorities
(details concerning the legally required approval from the
Albanian Cabinet are also missing). Details regarding further
treatment prior to dumping also remain unclear.
According to the report that France filed with the secretariat, the 588
tones of waste shipped to Albania in 2004 were classified as Y- 17.
Report published by the European Environmental Agency in
November 2010 underlined that Albania has “no system for the safe
management” of hazardous waste.
The report noted that “Hazardous waste generated by the
industrial sector and municipal wastes are deposited together
with urban waste”
Are there cases brought before the courts and supreme courts
on ENvCr &
maritime pollution?
 One of the main problems for the marine pollution in Albania are the illegal
constructions, frequently accompanied by solid waste discharges into the
sea or by extending basements with stones and inert materials inside the
sea in order to build other constructions
 Such, situation according to art. 203 of the Criminal Code
constitutes an environmental crime.
 In some cases administrative sanctions have been applied but no removal
of the pollution has been ordered. In some other cases interviews given
by local actors like Environmental Inspectorate, or local Municipality
officials makes it clear that there is a big lake of coordination and training
of members operating in such structures.
Case under
prosecution
The complex with two apartment buildings is being
constructed on a basement that was extended with
stones and inert materials inside the sea, and the
construction company has shown the permit on a
billboard.
But the environment chief inspector, declared that
inspectors have fined the company for violating
regulations and surpassing the limits of the permit. The
fine is 2 million ALL, but the work is still going on (up to
2011)
Environment Inspectorate says that they do not have the
competences for stopping the construction works. Vlore
Municipality officials refused to speak for this case, but
they declared that they have suspended the construction
works once. In the meantime there have been no
interventions by the construction inspectorate and the
police. Sources from Vlore prosecution declared that this
prosecution will soon inspect the construction. The
prosecution declared that they have opened the case .
Illegal mini-piers builders
fined (Vlore)
The Regional Environmental Director,
showed the punitive measures that
were given to mini-pier constructors,
mainly
fines.
Despite these fines, the illegal
constructions are still going on and
local authorities have not stopped
them.
No one of the violators has been
criminally charged.
Wastewater descharge
Diractorate of Environmental Control
« drastic action plan 2011»
 In order to stop such discharges into the sea, on 2011, the Directorate of
Environmental Control took some drastic measures for those cases when
illegal discharges of wastewater into the sea were met.
 In these cases the “action plan” provides for destruction of sewerages that
goes into the sea – and in case of repeated infraction notice will be given
to the competent institution for criminal prosecution.
 The same prosecution is intended to be held also for local government
executives in those cases where the permits are given without the correct
environmental impact assessment certifies.
Environmental Agencies report 2010 - 2011
 during 2010-2011 fines have been imposed to over 240 entities
and over 135 other have been submitted to the measures of
“suspending activities” due the control of discharge of wastewater.
 During 2011 over 19 municipalities have been fined by the
Environmental Agencies
 Also the pipes of west water discharges without filters, in most
beaches have been removed but the situation is still far from being
resolved, because now in some places the discharge is made
directly in the send ( Golem – Mali I Robit)
Conclusione
 The Albanian Government is still pursuing with the
harmonization of its national legislation with the
European Union environmental one.
 2011 new package of laws dealing with environmental
issues
 Lack of coordination among the differente institutiones
 Ministre of Justice and prosecutors need to be more
involved
Thank you!
Entela Cukani