Fayed (F) wanted to take over a company and a parliamentary commission undertook a public report into his conduct which X had attacked.
The report was bad for F who argued that its contents breached Article 6 – Right to a fair trial and to be heard before a tribunal.
European Court of Human Rights said that Article 6 was only engaged where there was a dispute decisively determining F’s civil rights or obligations.
Clearly that wasn’t the case here so Article 6 wasn’t engaged.
Here, the parliamentary committee was carrying out an investigatory function.