3. The European Convention on Human Rights

In R 19/12 of 25 April 2014 date: 2014-04-25 the Enlarged Board of Appeal observed that Article 6 ECHR had been recognised in G 1/05 date: 2006-12-07 (OJ 2007, 362) and G 2/08 of 15 June 2009 date: 2009-06-15 as a binding standard for proceedings before the boards of appeal because it relied on principles of law common to all member states of the European Patent Organisation and applying to all its departments (see also D 11/91 of 14 September 1994 date: 1994-09-14 and chapter III.J.1.3. "The Convention for the Protection of Human Rights and Fundamental Freedoms"). That justified applying both national case law and that of the European Court of Human Rights as a supplementary means of interpreting the EPC.