An applicant for judicial review who has not constituted a lawyer and has not lodged his statement of case within the time limit provided for in Article 584 shall forfeit his appeal.
The same applies, unless an exemption is granted by the President of the Criminal Division, to an applicant who has been convicted of a criminal offence and who has not instructed a lawyer and to the Public Prosecutor’s Office who have not sent their statement of case to the Registry of the Court of Cassation within the time limits laid down, respectively, in the first paragraph of Article 585-1 and in article 585-2.
An applicant sentenced to a penalty not provided for by law may not, however, forfeit his appeal.