Statute of limitations under the penal law of Bulgaria

Regarding the crime of systematic perpetration, it also consists of similar acts but they must be three, at least. More importantly, unlike the continued crime, the crime of systematic perpetration is not possible with all criminal offences. Only several criminal offences might be perpetrated as such a complicated crime. There are two different kinds of this complicated criminal activity. The first one comprises the cases where the separate acts are not criminal on their own. These are the so-called typical crimes of systematic perpetration, e.g. three or more non-licensed financial transactions - Article 253 PC. The other kind of this complicated criminal activity comprises the cases where the separate acts are criminal on their own also; these are the so-called untypical crimes of systematic perpetration, e.g. the taking away a motor vehicle to solely make use of it. Each of the constituting acts is criminalized separately by Article 346 (1) PC, whereas their systematic perpetration carries a heavier punishment under Paragraph 2 (ii) of the same Article for the entire criminal activity. In all cases of such activity {typical or untypical}, the limitation period commences running once the criminal activity is accomplished, namely: on the day of the last act.

What must be remembered is that the consecutive acts of this complicated criminal activity are similar. This is why they may constitute in their totality a continuous offence - Article 26 PC. In such situations, the provisions on the crime of systematic perpetration are not applicable. This complicated activity is qualified only as a continuous offence with all three aforementioned exceptions to its existence under Article 26 (6) PC.

Bulgarian penal law does not stipulate any common limitation period, the expiry of which extinguishes the criminal liability of the offender, like the five-year “lustrum” (Lat. Purification) in Roman times. The limitation periods are differentiated by law. The differentiation is based on the maximum punishments provided by the PC for the different crimes. The periods are set out in Article 80: (a) twenty years in respect of acts punishable by life imprisonment without substitution or life imprisonment, and 35 years in respect of the murder of two or more persons; (b) fifteen years with respect to acts punishable by imprisonment for more than ten years; (c) ten years with respect to acts punishable by imprisonment for more than three years; (d) five years in respect of acts punishable by imprisonment for more than one year, and (e) there years in respect of all remaining cases. The periods for crimes committed by underage persons shall be determined after taking into consideration the reduced punishments for them by the virtue of Article 63 PC.

In cases of positive post-criminal behaviour which entails the reduction of the punishments provided for in the PC (2-6) - imprisonment of up to eight years; 5. in the cases of Article 196a - imprisonment from eight to twenty years''., the length of the limitation period shall be calculated based on its reduction. Besides, according to Item 2 the Interpretative Decision No. 26/1960 of the General Assembly of the Criminal Collegia of the Bulgarian Supreme Court, this period shall commence running on the day when the behaviour was accomplished if this would be more favourable to the offender [4, 519].

The limitation period is not just a period of running time. Essentially, it is a period of inaction by the competent judiciary bodies that shall prosecute and try the offender. Per argumentum a contrario, if these bodies undertake the necessary actions, no limitation period shall exist. Their actions would exclude it; they would interrupt this period.

Pursuant to Article 81 (2) PC, the limitation period is interrupted by every act of prosecution undertaken against the offender by the competent judicial bodies. The interruption affects only the person against whom the prosecution act is being directed. The interruption means that all the time that has expired so far loses legal significance; it shall not be counted any more for the extinction of the offender's criminal liability. Besides, during the time, when the act of prosecution is being performed, no limitation period may run. Only after the completion of this act, which interrupts the limitation period, a new period shall commence running, as though the crime were committed on the last day of the prosecution act.

Such acts not only target a specific offender but aim at punishing him/her, e.g. the constitution of the suspected offender as an accused person, service of summons on him/her in this capacity, his/her official interrogation, confrontation with other accused or/and witnesses, presentation of the investigation materials to him/her, submission of indictment against the accused to court, etc [6] See Decision No. 28/1959 of the General Assembly of the Criminal Collegia of the Bulgarian Supreme Court of Cassation.. There is no indicative list of these grounds, let alone an exhaustive one in Bulgarian law. This is why it is, sometimes, a matter of interpretation to decide whether some act constitutes prosecution of the offender and therefore, shall interrupt the limitation period.

The interruption must be distinguished from the other impediment to the limitation period, namely: the suspension of this period. Whereas its interruption invalidates the time which has run so far, the suspension preserves it: therefore, this suspension “freezes” the limitation period that has run so far. Thus, the time of suspension shall not be counted into the period of limitation E.g. Section 34 (1) of the Czech Criminal Code. but once the suspension ground is over, this period shall continiue to run.

Under Article 81 (1) PC, the suspension of the limitation period for criminal liability takes place whenever the initiation or the continuation of the prosecution depends upon the solution of some preliminary issue with some judicial decision that cannot be produced in criminal proceedings, e.g. some civil law dispute. For instance, if the person suspected of theft claims to be the owner of the allegedly stolen item and therefore, s/he cannot steal it. Such a legal dispute is solvable outside the criminal proceedings, by a civil court only. Until proven by a court decision that the suspect is not the owner, the limitation period stays “frozen” and may restart only after the delivery of the court decision. Suspension should also take place even when the crime and the offender's responsibility have been proven if the implementation of his/her criminal liability is not feasible until some circumstance occurs, esp. one producible by a court. For instance, the liability for the accomplished compulsory marriage under Article 177 (1) PC is entirely blocked until the marriage is proclaimed null and void by the court on the grounds of the compulsion exercised. In such cases, the limitation period should start running only after the court decision.

It is noteworthy that necessary administrative decisions, e.g. permission for the prosecution of an offender with a specific status, though also producible beyond criminal proceedings, do not suspend the limitation period. Such non-judicial decisions triggered its suspension under Article 73 of the first Bulgarian Penal Law (1896) but this rule was not reproduced later in the following Penal Codes (1951-6 and 1968).

The rationale behind any such suspension of the limitation period is the legal impossibility of proceeding with the criminal case if a necessary court decision is missing. Its absence constitutes a judicial obstacle (Fr.: obstacle de droit) creating a judicial impossibility to prosecute the offender (Fr.: impossibilite de droit). Bulgarian law has never recognized the factual impossibility to prosecute the offender (Fr.: impossibilite de fait) as any suspending factor, e.g. because of war, earthquake or nuclear disaster, and has never upgraded any such difficulty to a ground of suspension. Hence, no factual difficulties have been turned into grounds of suspension to make any of them a factual obstacle (Fr.: obstacle de fait) to the limitation period.

Finally, as pointed out supra, the prosecution act against the offender, interrupting the limitation period under Article 81 (2) CC, constitutes also a ground for suspension. The period cannot run when the prosecution act is underway. This act not only invalidates all the time which had run out so far from the end of the criminal activity but also prohibits the next limitation period from running. As far as the entire prosecution is a legal activity based on decisions, each of its acts might be qualified as a judicial obstacle similar to the decisions under Article 81 (1) PC.

The Bulgarian criminal law provides for the so-called absolute limitation period for imposition of punishments. According to Article 81 (3) PC, notwithstanding interruptions or/and suspensions, the offender's criminal liability extinguishes when a time, which exceeds by one half the period, provided by the quoted Article 80 PC for the general limitation period, expires if no punishment has been imposed. Thus, the absolute limitation period is not simply a time of inaction by the competent judicial bodies. It is a time when they have failed to achieve the required result, namely: the conviction of the offender. Otherwise, if even his/her conviction is not the missing negative element, the period of time under Article 81 (3) PC would not constitute any limitation period at all. What actually makes this period of time a limitation one is the non-conviction of the offender. The lack of such a conviction allows the absolute limitation period to expire.

Per argumentum a contrario, if the offender is convicted, even the absolute limitation period under Article 81 (3) PC cannot run out. It follows that this limitation period is inevitably interruptible by the conviction of the offender: a condemning criminal judgment imposing a punishment on him/her. Once this conviction occurs, no statute of limitations is relevant, including the absolute one. Yet, if exceptionally, the judgment is overturned by some of the extraordinary remedies for its review, then, obviously, a new limitation period of both general and absolute period shall restart as nothing impedes its running Article 66 (5) [Amended on 29 June 2005 - By Article 8 of the Law no. 5377] of the Turkish Penal Code, dealing with this issue, reads as follows: “In the case of a retrial for the same act, the limitation period for that particular act starts again from the date the court accepts the application for the retrial'. See also Articles 311-323 of the Criminal Procedure Code of Turkey on this extraordinary legal remedy.

The issue of impeding the absolute limitation period is not regulated in the Bulgarian PC. However, it is important that the PC expressly recognizes the judgment in force as a ground of suspension of the absolute limitation period. Besides, it must be decided in the PC whether the executed part of the already imposed punishment, if any, should be deducted from the maximum punishment by law to reduce the new period, accordingly, given the possible maximum of the new punishment E.g. 4 years imprisonment were imposed for a crime carrying by law up to five years of this punishment with a limitation period for criminal liability of ten years - Article 80 (1) (iii) PC. Before overturning the judgment the offender served 3 years; after their deduction, 2 years of maximum imprisonment are left, they reduce the limitation period to five years - Article 80 (1) (iv) PC..

3. Limitation Period for Execution of the Punishment

This limitation period entails on expiry the extinction of only one of the possible substantive penal law consequences of the committed crime: the imposed punishment, its second consequence. On the one hand, the limitation period in the issue expires when the first consequence of the crime, the criminal liability has already been implemented through the condemning judgment on the offender whereby s/he was punished. On the other hand, this limitation period does not affect the third consequence of the crime, the offender's conviction. This consequence is erasable by the rehabilitation of the offender (Articles 85-88a PC) or some amnesty of his/her committed crime (Article 83 PC).

This second type of limitation period is a time when the punishment imposed on the offender shall be executed. But it is also such a period of time when the competent state bodies have failed to execute the punishment. On the expiry of this period of their inaction, the punishment imposed on the offender extinguishes In Poland, the `expunction' of the punishment occurs as “the sentence is considered non-existent'' anymore - Article 106 of the Polish PC. and s/he shall never serve it. Therefore, this limitation period provides the deadline to the competent state bodies for the execution of the punishment. It is a time not only for the institution on paper of the legal proceedings for the execution of the imposed punishment but it is also a time for achieving this execution. Otherwise, if this time period runs out and the sentenced offender has not started serving his/her punishment, s/he shall be unconditionally and irreversibly free from it. As in the case of the first type of limitation period, the behaviour of the convict is irrelevant under Bulgarian law. The favourable result is not any reward to him/her for good behaviour, contrary to the situation with the rehabilitation by law where its favourable result of erasing the conviction may occur only if the sentenced offender does not commit crimes during the rehabilitation period - see Article 86 PC.

The result of the expiry of this limitation period not only prevents the punishment from being executed. The non-executability of the punishment imposed on the convict opens the way to his/her rehabilitation by law as well. In view thereof, the General Assembly of the Criminal Collegia of the Bulgarian Supreme Court of Cassation ruled that rehabilitation by law may also take place if the punishment imposed has extinguished because of the expiry of the limitation period - Item 1 of the Interpretative Decision No. 2/2018 of the General Assembly The text is in the Bulgarian language only, available at http://www.vks.bg/talkuvatelni-dela-osnk/ vks-osnk-tdelo-2017-2-reshenie.pdf (translation by the author)..

It is worth noting that rehabilitation by law after the expiry of the limitation period has not been expressly provided for in Bulgarian law. According to Article 86 (1) (i) PC, if the punishment has not been served, rehabilitation by law may occur after the expiry of a probation period (Articles 66 and 69 PC) if the convict has not committed new crimes. However, this is not the only such situation where the punishment becomes inexecutable without being served by the convict. Obviously, as in the case discussed, if the punishment has been extinguished by an expired limitation period, this punishment is also inexecutable without being served.

The conclusion that rehabilitation by law may take place also in cases of expired limitation periods, comes from the application by statutory analogy [analogia legis] of the aforementioned Article 86 (1) (i) PC. All conditions for such an analogy are met. First, there is a gap (lacuna) in law because the relations between the limitation period extinguishing the punishment and the rehabilitation by law should be legally regulated in some way but they are not. Second, there is a provision applicable to a similar situation: this is Article 86 (1) (i) PC which also envisages a case of punishment that has become inexecutable without being served by the convict. Third, the application of Article 86 (1) (i) PC by analogy brings a favourable result to the person concerned. This is the convict who would benefit from having the opportunity to be rehabilitated once Article 86 (1) (i) PC applies.

Undoubtedly, the text of Article 86 (1) (i) PC needs some further improvement. It should codify all situations of non-executability of the punishment imposed on the convict to prescribe that they all open the way to his/her rehabilitation. If these grounds for the start of the rehabilitation period are codified in a general text, no one of them would be missed.

Once this second type of limitation period expires the punishment imposed on the offender would extinguish as a result of the competent state bodies' inaction. This necessarily means that the limitation period makes sense if and when the state bodies shall act to achieve the execution of the punishment. It follows that the limitation period in the issue cannot start running before the state bodies get obliged to proceed with the execution of the punishment. According to Article 82 (2) PC, “the limitation period extinguishing the punishment shall commence as from the day the sentence has entered into force, and with regard to punishment with a suspended sentence, according to Article 66 - as from the entry into force of the sentence or the court ruling under Article 68”.

Therefore, if the sentence is not suspended, the limitation period starts running on the day when the judgment becomes effective - Article 412 (2) CPC. As soon as the judgment becomes effective, the punishment imposed is executable and the competent state bodies shall take steps for its execution.

However, if the sentence has been suspended as per Article 66 PC, then the judgment, though effective, does not produce an executable punishment. The punishment imposed on the convicted offender may become executable only after the conditions under Article 68 PC are met and eventually, the competent court activates it. Once the punishment is executable based on the court decision, the competent state bodies shall take steps to secure its execution. Only then the limitation period would be running. In view thereof, in the situation of suspended sentences, the period shall start on the day when the postponed punishment is activated by the competent court.

If an early release has been granted to a prisoner, the starting day would, likewise, be the one when the unserved part of his/her punishment is executable. This remaining part of the partially served punishment may become executable only after the conditions under Article 70 (7) PC are met and the court activates it. After the court decision, the competent state bodies shall take steps to secure its execution. Then the limitation period would be running. In view thereof, in the situation of early release, the limitation period shall start on the day when the remaining part of the punishment is activated by the competent court.

The executability of some punishments might be a problem in cases of cumulative sentences, containing two or more punishments of different nature - Article 57 (2) PC, if the execution of one of them shall be carried out first and prevent the simultaneous service of the other(s). Such other punishment(s) are neither servable before the “priority” punishment nor can be executed during its execution. Most often, the imprisonment punishment in a cumulative sentence is executable first to eventually exclude the simultaneous service of probation, also a criminal punishment under Bulgarian law - Articles 42a and 42b PC. This is why, until the execution of the former punishment is over, the latter one is inexecutable. Taking this into consideration the non-executability of the probation punishment at the time when the “priority” imprisonment punishment shall be served or is being served by the convict, the General Assembly of the Criminal Collegia of the Bulgarian Supreme Court of Cassation ruled that in such situations no limitation period shall run for the probation punishment - Item 1 of the Interpretative Decision No. 3/2017 of the General Assembly The text is in Bulgarian language only, available at http://www.vks.bg/talkuvatelni-dela-osnk/vks-osnk-tdelo-2017-3-reshenie.pdf (translation by the author).. The running of this period is suspended.

As in the case with the limitation periods, the expiry of which extinguishes the criminal liability, there is no general time limit for this second type of limitation periods either. However, the periods are also differentiated but based on the individual punishments imposed rather than the punishments prescribed by the PC. The specific limitation periods are set out in Article 82 PC: (a) twenty years if the punishment was life imprisonment without substitution or life imprisonment; (b) fifteen years if the punishment was imprisonment for more than ten years; (c) ten years if the punishment was imprisonment from three to ten years; (d) five years if the punishment was imprisonment for less than three years, and (e) two years for all remaining cases.

Under Article 82 (3) PC, the limitation period, on the expiry of which the punishment extinguishes, shall be interrupted if the competent state bodies take action for the execution of the punishment. Acts for its execution are sending the judgment by the court to the prosecutor for execution, issuing an order by the prosecutor to the prison or another competent authority to begin the execution, summoning of the convicted person to appear, etc. After the conclusion of any such act whereby the limitation period has been interrupted, a new period shall commence running, as though the punishment were executable on the day when the act was performed.

No ground of the suspension of the limitation period for the execution of the punishment exists in Bulgarian law. Hence, even if a judicial or another decision concerning the status of the convict is indispensable for the execution of the punishment imposed on him/her, the necessity of such a decision may not produce the legal effect of suspension. As explained with regard to the probation punishment, the suspension of this limitation period is also possible. The possibility of its suspension has been recognized also in the text of Article 82 (4) PC, infra. However, this is not achievable without a legal provision. In particular, the application by statutory analogy [analogia legis] of Article 81 (1) PC, which prescribes the suspension of the limitation period for criminal liability, is not feasible. No such analogy shall be resorted to in this case because the application Article 81 (1) PC would be detrimental to the convict: it would prolong the time of the extinction of his/her punishment. It is well-known that no analogy is allowed if the result would not be favourable to the persons concerned. Apart from this, such an analogy would violate Article 46 (2) (1) of the Bulgaria Law on the Normative Acts as it would be contrary to the rules of social ethics, at least.

Grounds of suspension of the limitation period for execution of the punishment should necessarily be provided for in the PC. In any case, they should be essentially similar to those under 81 (1) PC outlining the suspension of the limitation period for the imposition of the punishment (the criminal liability). These grounds for the suspension of the limitation period for execution of the punishment should also be based only on legal impossibility. No factual impossibility should be upgraded to a ground of suspension The Serbian PC, for example, contains such a rule. This is Article 107 (3): “Limitation shall not run during the period when enforcement of penalty may not be undertaken by law.''.

There is an absolute limitation period for the execution of imposed punishments as well. According to Article 82 (4) PC, irrespective of any interruptions or/and suspensions, the imposed punishment gets extinct and, therefore, shall never be executed if a time which exceeds by one half the period, provided by the quoted Article 82 PC for the general limitation period, expired and no execution of the punishment took place.

As in the situation with the absolute limitation period for criminal liability, the legal framework for this type of absolute limitation period is underdeveloped. It consists of two paragraphs only: Paragraph 4 and 5 of Article 82 PC. They give no answers to important questions. Thus, since this is also some limitation period, what might be the state bodies' activity/results which if not undertaken/achieved would allow the running of this period and even its expiry? Obviously, the actual execution of the punishment, at least, shall interrupt this limitation period; preceding acts of the court, the prosecutor, the prison or other competent administration, however, shall not.

Besides, if part of the punishment has been executed or pardoned and the convict is not serving it at the moment, what shall be the length of the limitation period for the remaining part of the punishment: shall it be calculated on the basis of the imposed punishment or only the unserved remaining part shall be taken into consideration? If the remaining part is incomparably smaller than the imposed punishment, the preservation of the initial limitation period can be hardly justified.

The issues of interruption and suspension of this absolute limitation period should not be overlooked either. If the execution of the punishment is underway, it makes sense to accept that no limitation period may run. It is interrupted and may commence running only if the execution stops before the entire punishment has been served. In the meantime, while the execution is ongoing, this activity of the competent state bodies should exclude the running of any limitation period. Obviously, no period shall run during the execution of the punishment, let alone expire in full. The execution should suspend it whenever an executable part of the punishment remains unserved. Therefore, the execution in the issue not only invalidates all the time which has run out from its start but also prohibits any new limitation period from running.

A legislative attempt to regulate - in part, at least, - the interruption and suspension of the absolute limitation period was made. In 1982, a new Paragraph 5 was inserted in Article 82 PC. It was designed to exclude the absolute limitation period under the preceding Paragraph 4 of the Article. The new Paragraph 5 reads: “The provision of the preceding Paragraph shall not apply to a fine, where enforcement proceedings have been started for its collection.” This means that the institution of legal proceedings for the execution of this punishment (Article 47 PC) is sufficient for the interruption of the absolute limitation period and its suspension as well. Hence, it is not necessary that any actual collection of the imposed fine has begun.

The institution of enforcement proceedings for the collection of the fine, however, is an act of the competent state body for the execution of the punishment.

As any other such act, it interrupts and suspends the general limitation period. In addition, in the particular case with fines, the act in the issue entails under the new Paragraph 5 also the interruption and suspension of the absolute limitation period. The problem is that such acts concern legal proceedings and modify only general limitation periods when it comes to other punishments. To avoid discrepancies with their absolute limitation periods, it would be recommendable to turn into a ground for interruption and suspension only the actual collection of the imposed fine.

Besides, it seems that the interruption and suspensions of the absolute limitation period for the imposed fine last forever, even when the enforcement proceedings are discontinued. However, if the proceedings are discontinued and some amount of the imposed fine is still subject to collection, it hardly makes any sense to have no absolute limitation period for the uncollected fine. If no such proceedings are in existence, nothing should impede the running of this period. By the way, this view was accepted by the Bulgarian Supreme Court of Cassation [supra, Interpretative Decision No. 2/2018 of the General Assembly of the Criminal Collegia - Item 4 (ii); see footnote 23] but must be legislatively implemented in the PC as a clear legal provision.

At the same time, the absolute limitation period shall be legally regulated for all criminal punishments rather than only for the fine under Article 47 PC. This issue needs proper codification.

Conclusions

A strange inversion exists in Bulgarian law. The CPC [Article 24 (1) (iii), in particular] expresses and confirms the concept that the expiry of the limitation period produces a substantive law effect, namely: the termination of the criminal liability of the offender. This provision bars criminal proceedings if “the criminal liability has been extinguished by the expiry of the limitation period”. At the same time, the Bulgarian PC resorts to the traditional (actually, outdated) terminology indicating only procedural effects. Article 80 (1) of this Code read that if the above- mentioned limitation period expires, “criminal prosecution shall be excluded...”

The Bulgarian judicial practice, though, has overcome this understanding that the statute of limitations is a procedural institution by accepting that the expiry of the limitation period impedes primarily the imposition of the punishment on the offender rather than his/her prosecution only. Thus, substantive law consequences are produced: the imposition of punishment by the competent state authorities has been excluded. From the offender's point of view, this means the extinction of his/her criminal liability for the committed criminal offence. Hence, this type of limitation period is not only a time frame within which criminal proceedings must be instituted. It is, most of all, a deadline for the conviction of the offender. Obviously, the respective texts of the Bulgarian PC should be improved to embed the substantive law nature and effect of this statute of limitations.

The substantive law nature and effect of the limitation period for the execution of punishment should not cast any doubts either. Otherwise, this period would not be distinguished from the prescription in civil law which produces solely a procedural effect: extinguishes the action, but not the substantive right of the creditor. Besides, the legal framework for this second type of limitation period should be supplemented by a rule on the grounds for its suspension. Presently, a gap on this issue exists.

The Bulgarian legal framework for the absolute limitation period [Article 81 (3) and Article 82 (4 and 5) PC] is underdeveloped. These Articles clarify what does not interrupt and suspend the limitation period but contain no indication as to what may interrupt or suspend it. The only exception is Article 82 (5) PC. It concerns the execution of the fine. Undoubtedly, this only provision on the interruption or the suspension of the absolute limitation period is far from sufficient. Apart from its insufficiency, it needs some additional rules to specify what happens with the absolute limitation period after the conclusion of the ground of its interruption and suspension, namely: the fine collection, if the whole fine has not been collected yet.

Lastly, as international judicial cooperation constantly intensifies, the significance of time limitations/ lapse of time as its impediment will grow for all European countries, including Bulgaria and Ukraine. See Article 10 of the European Convention on Extradition, Article 10, letter “C” and Article 11, letters “F” and “G” of the European Convention on the Transfer of Proceedings in Criminal Matters, Article 6, letter “L” of the European Convention on the International Validity of Criminal Judgments, etc.

Список літератури

1. Гиргинов А. Давността в наказателно право. София, 1992. 187 с.

2. Доковска Д. Процесуални проблеми на производството, което се образува по тъжба на пострадалия. София, 1983.

3. Митов Г. Наказателни дела от частен характер. София, 2017. 292 с.

4. Ненов И. Наказателно право на Народна Република България, 2-ро изд. София: Наука и изкуство, 1972. 541 с.

5. Станков Б. За правната същност на наказателната давност. Правна мисъл. 1992. № 4. С. 57-62.

6. Стойнов А. Наказателно право, обща част. София, 1999. 484 с.

References

1. Girginov, A. (1992). The Statute of limitations in criminal law. Sofia [in Bulgarian].

2. Dokovska, D. (1983). Procedural problems of the proceedings instituted on the complaint of the injured party Sofia [in Bulgarian].

3. Mytov, G. (2017). Criminal cases of private character. Sofia [in Bulgarian].

4. Nenov, I. (1972). The criminal law of the People's Republic of Bulgaria. 2-ed. Sofia [in Bulgarian].

5. Stankov, B. (1992). On the legal nature of the criminal statute of limitations. Pravna Misal - Legal Thought, 4, 57-62. Sofia [in Bulgarian].

6. Stoynov A. (1999). Criminal Law, the general part. Sofia [in Bulgarian].

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