The Court said
93. The right is not absolute, however. It may be subject to legitimate restrictions such as statutory limitation periods, security for costs orders, regulations concerning minors and persons of unsound mind
(see Stubbings and Others v. the United Kingdom, judgment of 22 October 1996, Reports 1996-IV, pp. 1502-03, §§ 51-52; Tolstoy Miloslavsky v. the United Kingdom, judgment of 13 July 1995, Series A no. 316-B, pp. 80-81, §§ 62-67; and Golder, cited above, p. 19, § 39).
Where the individual’s access is limited either by operation of law or in fact, the Court will examine whether the limitation imposed impaired the essence of the right and, in particular, whether it pursued a legitimate aim and there was a reasonable relationship of proportionality between the means employed and the aim sought to be achieved
(see Ashingdane v. the United Kingdom, judgment of 28 May 1985, Series A no. 93, pp. 24-25, § 57).
If the restriction is compatible with these principles, no violation of Article 6 will arise.
[Formatted for ease of reading. For material on how the ECHR itself deals with litigants who fail to engage with the process see Rules 43 [here], and rules 44A-44E [here] of the ECHR rules of Court 14th November 2016.]