The Disciplinary Panel reprimanded the prosecutor for culpable breach of duty

The Disciplinary Panel of the Supreme Administrative Court of the Slovak Republic ruled on the guilt of the disciplinary accused prosecutor of the District Prosecutor’s Office of Banská Bystrica, JUDr. Pavlína Zlochová, and punished her with a written reprimand. It did so by decision Case No. 33D/4/2025 dated October 30, 2025.

The Disciplinary Panel found the prosecutor, who was subject to disciplinary action, guilty of a disciplinary offence consisting in her actions culpably violating her duties – to fulfill the obligations arising from the laws, the obligation to protect the public interest and serve the public interest, and the obligation to perform her official duties conscientiously pursuant to Section 26, paragraph 1, letters a), b) and c) of Act No. 154/2001 Coll. on Prosecutors and Legal Trainees of the Prosecutor’s Office, as amended (hereinafter referred to as the “Act on Prosecutors”).

The prosecutor committed a disciplinary offense by failing to exercise all the powers of the supervising prosecutor during the 48-hour detention period, in her capacity as a prosecutor in a criminal case against a juvenile accused of making a dangerous threat, in which she granted a temporary consent to detain the juvenile suspect, and thereby passively accepted the extremely slow and drawn-out course of the investigation conducted during the period of detention of the juvenile. As a result, the accused juvenile was not heard within the 48-hour detention period. Nevertheless, the prosecutor did not propose to release the juvenile, but submitted an investigation file to the pre-trial judge with a proposal to take the accused into custody. After reviewing the documents, the pre-trial judge had to release the juvenile accused due to failure to meet the formal conditions for taking the accused into custody.

According to the Disciplinary Panel, by doing so, the prosecutor resigned from exercising her supervisory powers over compliance with the law in the preparatory proceedings and thereby jeopardized the achievement of the purpose of the criminal proceedings, i.e., by her actions, she committed a violation of the aforementioned duties of the prosecutor.

A disciplinary measure – a written reprimand – was imposed on the prosecutor facing disciplinary charges. When determining the penalty, the disciplinary panel took into account the fact that the prosecutor has had a very long career to date, which has been evaluated very positively and without any disciplinary offenses, and therefore chose a less invasive sanction. The disciplinary panel considered the written reprimand to be a sufficient disciplinary measure from both a punitive and a preventative perspective.

There is no appeal against the decision. The decision of the disciplinary panel was adopted by a vote of 5:0.

The decision was made by Panel No. 33D of the Supreme Administrative Court, composed of: President of the Panel Prof. JUDr. Juraj Vačok, PhD., Judges JUDr. Viola Takáčová, PhD., LL.M. and JUDr. Michal Dzurdzík, PhD. and Lay Judges JUDr. Viliam Gaži and JUDr. Karolína Staroňová.