The Disciplinary Panel Imposed a Monetary Fine on the Notary for Failing to Respond to a Complaint; Acquitted Her in the Signature Verification Matter
On 30th September 2025, the Disciplinary Panel of the Supreme Administrative Court of the Slovak Republic, in Case No. 31D/4/2024, ruled in the disciplinary matter of notary JUD. Ingrid Dubasová. In the first act, she was found guilty of violating her duty imposed by the Presidium of the Slovak Chamber of Notaries (hereinafter referred to as the “Notarial Chamber”) by failing to respond to a request to reply to a complaint. In the second act, concerning the certification of a businessperson’s signature, the Supreme Administrative Court acquitted her.
The Disciplinary Panel found that the accused notary committed a disciplinary offense under § 91(1) of the Notarial Code by failing to respond to correspondence sent by the Notarial Chamber and its representatives. For this act, to which she pleaded guilty, the notary was sanctioned with a disciplinary measure – a monetary fine of 700€.
The panel also assessed the second act, in which the notary was accused of certifying the authenticity of a signature while the individual was hospitalized in a rehabilitation facility. She was alleged to have improperly performed the certification due to the individual’s significantly reduced cognitive abilities and inability to comprehend written language at the time. It was further alleged that the notary repeatedly visited the individual and sought contact in a potentially forceful manner. However, the panel concluded that it was not proven that the individual was clearly incapable of understanding the certification process at the time of signing. It was also not proven that the notary used forceful means to establish contact.
The decision on guilt in the first act was unanimous, with all four members of the disciplinary panel voting in favor of the imposed penalty. No appeal is permitted against this ruling. In the second act, the vote on guilt was 3 to 2, and the disciplinary petitioner may appeal this decision.
The decision was adopted by Panel No. 31 of the Supreme Administrative Court, composed of:
President of the panel: Prof. JUDr. Juraj Vačok, PhD.
Members of the panel: Mgr. Michal Novotný, JUDr. Zuzana Šabová, PhD., JUDr. Ľubica Bičanová, JUDr. Ivan Macák.