-20requirements of Article 13 are to be seen as reinforcing those of Article 6(1), rather than being absorbed by the general obligation imposed by that Article not to subject individuals to inordinate delays in legal proceedings" (para. 152). 57. And the European Court concluded, in this regard, in the said Kudla v. Poland, that "the correct interpretation of Article 13 is that that provision guarantees an effective recourse before a national authority for an alleged breach of the requirement under Article 6(1) to hear a case within a reasonable time" (para. 156). Consequently, the Court determined that in the specific case, "there has been a violation of Article 13 of the Convention in that the applicant had no domestic remedy whereby he could enforce his right to a 'hearing within a reasonable time' as guaranteed by Article 6(1) of the Convention" (para. 160). 58. In reality, in recent years (since the end of the 1960s), in successive cases, the European Court has taken into account the requirements of due process of law (Article 6 of the European Convention) in direct correlation with those of the right to an effective recourse (Article 13 of the Convention).45 The right to an effective recourse in developing European case law incorporates the rule of law, and cannot be disassociated from the rule of law in a democratic society.46 Its material content as a subjective and autonomous right characterizes it as “a fundamental instrument for the implementation of the protection of human rights."47 59. Fortunately, the case law of the Inter-American Court has dispensed with the vicissitudes of the case law of its European namesake, whose actual position on this matter is, as we have seen, similar to that of the Inter-American Court. To try and disassociate Articles 25 and 8 of the American Convention would be inadmissible, for this reason also, and would constitute a return to the pre-history of the case law of our Court. It is unfortunate that, within the Inter-American Court, I am obliged to continue trying to avoid a serious setback in the Court’s case law, rather than the Court following its advanced case law in this respect. X. The right of access to justice lato sensu. 60. During a 1996 Colloquium held by Strasbourg University and the Cour de Cassation on "Les nouveaux développements du procès équitable" within the framework of the European Convention on Human Right, J.-F. Flauss underscored correctly, the close relationship between access to a court (by means of an effective recourse) and the procès équitable [right to a fair trial], and added that the right to a fair trial encompassed even the effective execution of the judgment in favor of the victim.48 On this point, the Colloquium concluded by expressly recognizing “the close 45 . For example, cf. M. de Salvia, Compendium de la CEDH - Les principes directeurs de la jurisprudence relative à la Convention européenne des droits de l'homme, Kehl/Strasbourg, Éd. Engel, 1998, p. 280. - From the outset, the European Court has rejected a restrictive interpretation of Article 6 of the European Convention, based on its "central" and "prominent" position in the Convention and because it is linked to the general principles of law, including "the fundamental principle of the rule of law"; A. Grotrian, Article 6 of the European Convention on Human Rights - The Right to a Fair Trial, Strasbourg, C.E., 1994, p. 6. 46 . D.J. Harris, M. O'Boyle and C. Warbrick, Law of the European Convention on Human Rights, London, Butterworths, 1995, p. 461. 47 . A. Drzemczewski and C. Giakoumopoulos, "Article 13" in La Convention européenne des droits de l'Homme - Commentaire article par article (eds. L.-E. Pettiti, E. Decaux and P.-H. Imbert), Paris, Economica, 1995, pp. 474. 48 . J.-F. Flauss, "Les nouvelles frontières du procès équitable," in Les nouveaux développements du