9.  The applicant was born in 1953 and lives in Gabrovo. 10.  On 28 June 1996 she was arrested upon the order of a prosecutor and brought to a psychiatric clinic for an examination. She was detained for five days and then released.
She was again detained for a psychiatric examination on 28 August 1996. 
On 21 March 1997 the applicant was arrested and detained for a third time. She was brought to a psychiatric clinic where she was detained allegedly incommunicado until 4 April 1997. 11.  Upon the applicant's complaint, she was informed by letter of 28 March 1997 of the district health authorities that her detention had been ordered by a prosecutor in accordance with the law. The applicant allegedly submitted another complaint to the Ministry of Health on 25 April 1997 but never received an answer. 12.  A summary of the relevant domestic law and practice in respect of detention with the purpose to conduct psychiatric examinations is contained in the Court's judgment in the case of Varbanov v. Bulgaria (no. 31165/95, ECHR 2000-X). Paragraphs 28-32 of that judgment, insofar as relevant, read as follows:
“[Judicial proceedings for an order for compulsory psychiatric treatment] are instituted by a district prosecutor who is under the obligation to undertake a prior inquiry, including a psychiatric examination, in order to assess the need for instituting proceedings. The prosecutor therefore would normally invite the person concerned to undergo an examination in the framework of his inquiry.
The Public Health Act, as in force [until February 1997], did not contain a provision expressly authorising a prosecutor to order a person being brought by force to a hospital and his detention at the hospital for purposes of such a psychiatric examination... The relevant law did not provide for an appeal to a court in cases of persons detained for an examination in the framework of a district prosecutor's inquiry...
Certain amendments to the Public Health Act were introduced in February 1997... [providing] ... that a prosecutor, in the framework of his inquiry, can order confinement to a psychiatric hospital for up to 30 days (up to three months in exceptional cases) for the medical examination of a person who has refused to undergo such an examination voluntarily. However, no provision allowing judicial review of the prosecutor's order was introduced.
The Code of Criminal Procedure, by virtue of an amendment in force since 1 January 2000, introduced a judicial procedure for confinement in a psychiatric clinic of a person against whom criminal proceedings have been brought. This procedure, however, does not concern persons who have been confined in a clinic for a psychiatric examination pursuant to a prosecutor's order under Section 61 of the Public Health Act.” 13.  In the Varbanov case the Court made the following findings relevant to the present case (see paragraphs 43-53 of that judgment): 
“... the Public Health Act, as in force [until February 1997], did not contain any provision empowering prosecutors to commit a person to compulsory confinement in a psychiatric clinic for the purpose of effecting a psychiatric examination. 
Moreover, the applicable law, as in force at the relevant time and even after its amendment in 1997, does not provide for the seeking of a medical opinion as a pre-condition to ordering detention with a view to compulsory psychiatric examination and thus falls short of the required standard of protection against arbitrariness.
The Court thus finds a violation of Article 5 § 1 of the Convention on account of the fact that the applicant's deprivation of liberty was not justified under subparagraph (e) of this provision and had no basis in domestic law which, moreover, does not provide the required protection against arbitrariness as it does not require the seeking of a medical opinion.”