56 CYPRUS v. TURKEY JUDGMENT movement of the enclaved Greek Cypriots and hence on their access to courts. In the applicant Government's submission, these severe impediments to justice were confirmed by the findings in the “Karpas Brief”. 230. The Commission found on the facts that Greek Cypriots living in northern Cyprus were not prevented from bringing civil actions before the “TRNC” courts. In the Commission's conclusion, the applicant Government had not made out their claim that there was a practice in the “TRNC” of denying access to court. 231. As to the applicant Government's claim that “TRNC” courts failed to satisfy the criteria laid down in Article 6, the Commission noted, firstly, that there was nothing in the institutional framework of the “TRNC” legal system which was likely to cast doubt either on the independence and impartiality of the civil courts or the subjective and objective impartiality of judges, and, secondly, those courts functioned on the basis of the domestic law of the “TRNC” notwithstanding the unlawfulness under international law of the “TRNC”' s claim to statehood. The Commission found support for this view in the Advisory Opinion of the International Court of Justice in the Namibia case (see paragraph 86 above). Moreover, in the Commission's opinion due weight had to be given to the fact that the civil courts operating in the “TRNC” were in substance based on the Anglo-Saxon tradition and were not essentially different from the courts operating before the events of 1974 and from those which existed in the southern part of Cyprus. 232. The Commission accordingly concluded that, during the period under consideration, there had been no violation of Article 6 of the Convention in respect of Greek Cypriots living in northern Cyprus. 233. The Court notes that the applicant Government have confined their submissions under this head to the civil limb of Article 6 of the Convention. It recalls in this connection that the first paragraph of Article 6 embodies the right of access to a court or tribunal in respect of disputes over civil rights or obligations which can be said, at least on arguable grounds, to be recognised under domestic law; it does not of itself guarantee any particular content for such rights and obligations in the substantive law of the Contracting State (see, inter alia, the Lithgow and Others v. the United Kingdom judgment of 8 July 1986, Series A, no. 102, p. 70, § 192). Furthermore, a court or tribunal is characterised in the substantive sense of the term by its judicial function, that is to say determining matters within its competence on the basis of rules of law and after proceedings conducted in a prescribed manner. It must also satisfy a series of further requirements – independence, in particular of the executive; impartiality; duration of its members' terms of office; guarantees afforded by its procedure – several of which appear in the text of Article 6 § 1 (see, among other authorities, the Belilos v. Switzerland judgment of 29 April 1988, Series A no. 132, p. 29, § 64). 234. The Court observes that it is the applicant Government's contention that the enclaved Greek-Cypriot population is prevented, as a matter of