Délai de recours contre un acte administratif – Précisions jurisprudentielles récentes

 

L’article R. 421-1 du  Code de justice administrative prévoit qu’un acte administratif doit être contesté dans les deux mois suivants sa publication ou sa notification.

Toutefois, ce délai n’est opposable qu’à condition d’avoir été mentionné (y compris les voies de recours) dans l’acte.

Afin de garantir le principe de sécurité juridique qui implique que ne puissent être remises en cause indéfiniment des situations individuelles, le juge administratif a d’abord précisé que le délai de recours contre un acte administratif individuel était désormais limité à un an en cas d’absence de mentions des voies et délais de recours (CE, ass., 13 juill. 2016, n° 387763, Czabaj). 

Cette jurisprudence a été étendue en matière fiscale (CE, sect., 31 mars 2017, n° 389842, Min. Finances et Comptes publics c/ Amar).

Dans un arrêt du 9 mars 2018 (n°4001386 Communauté d’agglomération du pays ajaccien), le Conseil d’Etat a considéré que ce principe devait s’appliquer aux recours contre les titres exécutoires.

Afin d’éviter toute difficulté contentieuse, il est recommandé aux administrations de bien préciser les voies et délais de recours sur chaque acte administratif adopté

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