Strasbourg Observers

View posts from: Article 3

  • Sotiris Pafitis

Beyond Formal Compliance: Ineffective Investigations, Procedural Exclusion and Secondary Victimisation in X v. Georgia

May 08, 2026

By Sotiris Paphitis In its recent judgment in X v. Georgia, the European Court of Human Rights (ECtHR or the Court) was once again confronted with a question that has become increasingly prominent in its recent case-law on sexual violence: can a State be said to have complied with its positive obligations under Articles 3 and […]

  • Ananya Kumar-Banerjee

OH and Others v Serbia: Strasbourg’s Reliance on Domestic Judicial Organs in Pushbacks Cases

April 28, 2026

by Ananya Kumar-Banerjee Introduction On 3 February 2026, the European Court of Human Rights (“Strasbourg”) handed down OH and Others v Serbia (No. 57185/17) (“OH and Others”). Strasbourg considered whether the Serbian Government’s pushback of seventeen migrants into Bulgaria was in breach of the European Convention. Ultimately, the Court held that Serbia had breached Articles […]

  • Natasa Mavronicola

Closing reflections on Article 3 and Chişinǎu symposium

April 07, 2026

By dr. Natasa Mavronicola I am grateful to Strasbourg Observers for hosting this symposium on Article 3’s past, present and future, and to Mary Rogan, Rishika Sahgal, Eva Sevrin and Elaine Webster for this rich set of insights offered in the shadow of Chișinău. It is an honour to be among these authors and I […]

  • Mary Rogan

Prison conditions and Article 3 of the European Convention on Human Rights: What kinds of inhuman and degrading treatment are we now willing to accept?

April 06, 2026

By Professor Mary Rogan Prisons provide a special setting for the protections contained in Article 3 of the European Convention on Human Rights. It is well established that when liberty is deprived, the right to protection from torture and inhuman or degrading treatment or punishment is at particular risk (see further here, here, here and […]

  • Rishika Sahgal

Article 3 and the destruction of homes

April 03, 2026

By Dr Rishika Sahgal Introduction In the run-up to Chișinău, there has been increasing reference to the need to ‘constrain’ Article 3 of the European Convention on Human Rights (ECHR) to the ‘most serious issues’. The implication of such perspectives is that the interpretation of Article 3 has involved something of an overreach, and that […]

  • Elaine Webster

Has the interpretation of degrading treatment and punishment in Article 3 ECHR gone too far? A re-examination of Tyrer v UK

April 02, 2026

By Dr. Elaine Webster *** Strasbourg Observers is currently hosting a blog symposium on Article 3 of the ECHR and the forthcoming Chișinău Declaration, examining the ECtHR’s approach in migration cases. The symposium was convened by Natasa Mavronicola. It also features contributions from Mary Rogan, Rishika Sahgal, Eva Sevrin, and Elaine Webster. *** Questioning the […]

  • Eva Sevrin

Expulsion of Severely Ill migrants: Beyond the Deathbed, Still Exceptional

April 01, 2026

By Eva Sevrin *** Over the next 10 days, Strasbourg Observers will be hosting a blog symposium on Article 3 ECHR and the forthcoming Chișinău Declaration on the ECtHR’s approach in migration cases. The symposium was convened by Natasa Mavronicola. It also features contributions from Mary Rogan, Rishika Sahgal, Eva Sevrin, and Elaine Webster. *** […]

  • Natasa Mavronicola

Absoluteness affirmed and absoluteness denied: how the Chișinău process is reviving the ‘relatively absolute’ approach to Article 3

March 31, 2026

By Professor Natasa Mavronicola *** Strasbourg Observers is currently hosting a blog symposium on Article 3 ECHR and the forthcoming Chișinău Declaration on the ECtHR’s approach in migration cases. The symposium was convened by Natasa Mavronicola. It also features contributions from Mary Rogan, Rishika Sahgal, Eva Sevrin, and Elaine Webster. *** Introduction In 2013, Francesco […]

  • Natasa Mavronicola

Symposium Introduction: Article 3 ECHR and the forthcoming Chișinău Declaration

March 30, 2026

By Dr. Natasa Mavronicola *** Over the next 10 days, Strasbourg Observers will be hosting a blog symposium on Article 3 ECHR and the forthcoming Chișinău Declaration on the ECtHR’s approach in migration cases. The symposium was convened by Natasa Mavronicola. It also features contributions from Mary Rogan, Rishika Sahgal, Eva Sevrin, and Elaine Webster. […]

  • Alexander Hughes

Procedural violations found in sexual violence claims: was A.J. and L.E. v. Spain a progressive judgment or a foregone conclusion?

February 03, 2026

By Alexander Hughes The scope of the positive obligation on State authorities to conduct an effective investigation into allegations of sexual violence has once again come before the European Court of Human Rights in A.J. and L.E. v. Spain. The case concerns a regrettably familiar fate for many young women. The applicants alleged that they […]

  • Philipp Schönberger

E.A. and H.A.A. v. Greece: A U-Turn on Reception Conditions in Greek ‘Hotspots’

October 17, 2025

by Philipp Schönberger1 The European Court of Human Rights’ (ECtHR) inadmissibility decision in E.A. and H.A.A. v. Greece published on 4 September 2025 marks a potential turning point in its assessment of asylum seekers’ reception conditions in the Greek ‘hotspots.’ The case signals a regressive shift in the Court’s jurisprudence, one that lacks sound justification, but fits […]

  • Sam Chollet

A (binary) right to self-determination: T.H. v. Czech Republic

October 14, 2025

by Sam Chollet In T.H. v. Czech Republic, the European Court of Human Rights (ECtHR) reiterated that the requirement for trans* people to undergo genital surgery to have their gender legally recognised violates the right to private life. But this apparent victory for trans* rights represents a drawback for non-binary trans* people. Summary of the […]

  • Sibel Yılmaz Coşkun

Derrek and Others v. Russia: hesitancy on the path to a qualitative Article 3 threshold in LGBT-Phobia Cases?

August 27, 2025

By Sibel Yilmaz Coşkun          In its judgment of Derrek and Others v. Russia (29 April 2025; hereinafter Derrek), the European Court of Human Rights (the Court/ECtHR) addressed a police raid on an LGBT workshop, during which participants faced humiliating treatment and forced drug testing. The Court unanimously found violations of Articles 5 §1 and […]

  • Stefanos Xenofontos

State Complicity and the Gendered Architecture of Disbelief: A Critical Reading of N.T. v. Cyprus

August 22, 2025

by dr. Stefanos Xenofontos On 3 July 2025, the European Court of Human Rights (‘ECtHR’ or ‘the Court’) delivered its judgment in the case of N.T. v. Cyprus, unanimously finding violations of Articles 3, 8, and 14 of the European Convention on Human Rights (‘ECHR’) arising from the Cypriot authorities’ failure to effectively investigate and […]

  • Lorena Sosa

From institutionalisation to exploitation: structural failures and stereotyping in I.C. v. The Republic of Moldova

July 02, 2025

By Lorena Sosa The case of I.C. v. The Republic of Moldova intersects with two strands of ECtHR jurisprudence: (1) the Court’s developing understanding of sexual violence, rape and sexual exploitation, and (2) its evolving anti-stereotyping framework, particularly regarding persons with disabilities. Against the backdrop of landmark rulings, this judgment further enriches the Court’s often […]

  • Lorenza Grossi

Special Prison Regime and Cognitive Decline: The ECtHR Finds a Violation of Article 3 in Morabito v. Italy

May 16, 2025

By Lorenza Grossi The ECtHR examines the compatibility between special prison regimes and Article 3 ECHR. More precisely, under scrutiny is Article 41-bis of Law No. 354 of 26 July 1975 (the Italian Prison Law), also known as ‘hard prison.’ This provision allows the suspension of ordinary prison conditions – such as outdoor time and […]

  • Stephanie Motz and Annina Mullis

Undermining protection standards in pushbacks cases: The ECtHR in A.R.E. v. Greece and G.R.J. v. Greece

March 28, 2025

Stephanie Motz and Annina Mullis On 7 January 2025, the European Court of Human Rights (Court/ECtHR) published its findings in A.R.E. v. Greece and G.R.J. v. Greece. In these two cases, the Court adjudicated for the first time specifically on pushback allegations at the hands of Greek authorities. Both applications were part of a series of […]

  • Grażyna Baranowska

What – if any – are the consequences of the ‘instrumentalization of migration’ for human rights protection under the ECHR? A look at the arguments raised at the ECtHR Grand Chamber hearing on pushbacks to Belarus.

March 04, 2025

By Grazyna Baranowska On 12 February 2025, the Grand Chamber of the ECtHR held three hearings relating to pushback cases conducted by Poland, Latvia and Lithuania. The cases were relinquished to the Grand Chamber and heard in a single – very long – day, since all the alleged violations occurred within the same broader context […]

  • Louis Triaille

Clipea and Grosu v. the Republic of Moldova: an increasingly strict control on coercion and living conditions in psychiatric care

February 28, 2025

By Louis Triaille In its Clipea and Grosu v. the Republic of Moldova judgment, handed down on November 19, 2024, the European Court of Human Rights (ECtHR) clarifies States’ positive obligations to protect in-patients with mental disabilities from ill-treatment in psychiatric institutions. The judgment illustrates an increasingly strict scrutiny by the ECtHR on institutional psychiatry, […]

  • Alina Tryfonidou

Hanovs v. Latvia: Further clarification of the positive obligations of States in cases involving homophobic attacks

November 12, 2024

By Alina Tryfonidou The rise of homophobic and transphobic crime is a deeply troubling and pervasive issue in modern day Europe (see the FRA LGBTIQ Survey (2024), pp. 54-76). A key factor behind this is the growing wave of right-wing populism, which has contributed to an increasingly hostile social and political climate, where divisive rhetoric often targets […]

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