14 ANNAGI HAJIBEYLI v. AZERBAIJAN JUDGMENT v. Turkey, 16 September 1996, § 105, Reports 1996-IV, and Kurt v. Turkey, 25 May 1998, § 159, Reports 1998-III). In this context, “any form of pressure” includes not only direct coercion and flagrant acts of intimidation, but also other improper indirect acts or contacts designed to dissuade or discourage applicants from pursuing a Convention complaint or having a “chilling effect” on the exercise of the right of individual petition by applicants and their representatives (see Kurt, cited above, §§ 160 and 164; Tanrıkulu v. Turkey [GC], no. 23763/94, § 130, ECHR 1999-IV; and Fedotova v. Russia, no. 73225/01, § 48, 13 April 2006). 67. Whether or not contacts between the authorities and an applicant are tantamount to unacceptable practices from the standpoint of Article 34 must be determined in the light of the particular circumstances of the case (see Salman v. Turkey [GC], no. 21986/93, § 130, ECHR 2000-VII). 68. Furthermore, the Court has repeatedly held that persecution and harassment of members of the legal profession strikes at the very heart of the Convention system. Therefore, searches of lawyers’ premises should be subject to especially strict scrutiny (see Elçi and Others v. Turkey, nos. 23145/93 and 25091/94, § 669, 13 November 2003). 69. The Court has examined a number of cases concerning searches of lawyers’ offices under Article 8 of the Convention, finding that such searches amount to an interference with the lawyer’s “private life”, “home”, and “correspondence” (see Niemietz v. Germany, 16 December 1992, §§ 29-33, Series A no. 251-B; Tamosius v. the United Kingdom (dec.), no. 62002/00, ECHR 2002-VIII; Sallinen and Others v. Finland, no. 50882/99, §§ 70-72, 27 September 2005; Wieser and Bicos Beteiligungen GmbH v. Austria, no. 74336/01, §§ 43-45, ECHR 2007-IV; and Aleksanyan v. Russia, no. 46468/06, § 212, 22 December 2008). To determine whether a search was “necessary in a democratic society”, the Court has explored the availability of effective safeguards against abuse or arbitrariness under domestic law, and checked how those safeguards operated in the specific case under examination. Elements taken into consideration in this regard were the severity of the offence in connection with which the search and seizure were effected, whether they were carried out pursuant to a warrant issued by a judge or a judicial officer, whether the warrant was based on reasonable suspicion, and whether its scope was reasonably limited. The Court must also review the manner in which the search was executed, and, where a lawyer’s office is involved, whether it was carried out in the presence of an independent observer to ensure that material subject to legal professional privilege was not removed. The Court must finally take into account the extent of the possible repercussions on the work and the reputation of the persons affected by the search (see Aleksanyan, cited above, § 214, with further references). In cases where search warrants at issue were formulated in excessively broad terms, lacking any reservation in respect of privileged documents and giving the

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