The judgment in the case of *A.M. and Others v. Greece* (Applications nos. 11022/17 and 3 others), delivered on 24 September 2026, addresses the systemic failures of the Greek reception system for asylum-seekers. The Court examined four joined applications concerning individuals who endured substandard living conditions in various facilities, including the Ritsona camp and the Moria Reception and Identification Centre. The applicants, many of whom were identified as highly vulnerable due to physical disabilities, torture-related trauma, or chronic illnesses like HIV and Hepatitis B, alleged that their treatment violated Article 3 of the Convention. While the Court rejected certain claims due to a lack of substantiation or procedural time-limit issues, it found clear evidence of inhuman and degrading treatment in the majority of the cases. Ultimately, the Court ruled that the Greek authorities failed to provide adequate reception conditions and, in specific instances, failed to ensure timely access to essential medical care for vulnerable individuals.
The structure of the decision follows the standard format for a Committee-level judgment of the European Court of Human Rights. It begins with the procedural history and the joinder of the four applications, followed by an assessment of the admissibility of the complaints. The Court systematically addresses the Government’s preliminary objections regarding the exhaustion of domestic remedies and the applicants’ victim status, dismissing them by highlighting the lack of effective, accessible remedies in the Greek legal system for these specific grievances. The judgment then moves to the merits, relying heavily on the established case-law of *M.S.S. v. Belgium and Greece* and *Tarakhel v. Switzerland*. A significant feature of this judgment is the detailed appended table, which serves as an integral part of the decision, categorizing the specific vulnerabilities, the facilities involved, and the individual awards for non-pecuniary damage.
The most important provisions for legal practitioners and observers are as follows:
* **Threshold of Severity and Vulnerability:** The Court reaffirms that asylum-seekers are a “particularly vulnerable group.” It underscores that when an individual’s vulnerability (such as being a victim of torture or living with HIV) is known to the authorities, the State bears a heightened positive obligation to provide specialized, trauma-informed care.
* **Rejection of “Theoretical” Remedies:** The Court clarifies that the burden of proof lies with the Government to demonstrate that a domestic remedy is not only effective in theory but also in practice. The judgment explicitly states that if the Government cannot provide concrete examples of domestic case-law showing that a remedy provides timely redress for reception condition complaints, the objection of non-exhaustion of domestic remedies will be dismissed.
* **Medical Negligence as a Violation:** The judgment establishes that significant delays in initiating essential medical treatments (such as antiretroviral therapy for HIV) for vulnerable asylum-seekers, without clear clinical or administrative justification, constitute a violation of Article 3.
* **Procedural Rigor:** The Court emphasizes that applicants must provide “concrete and detailed information” regarding their personal situation. Failure to substantiate the duration and specific nature of alleged shortcomings leads to the rejection of claims as manifestly ill-founded.
**:** This decision is highly relevant for Ukraine and Ukrainian legal professionals, as it reinforces the standards for the treatment of displaced persons and vulnerable groups under the European Convention on Human Rights. The Court’s strict stance on the State’s positive obligation to provide adequate medical care and living conditions for vulnerable asylum-seekers provides a critical precedent for any proceedings involving the rights of refugees or internally displaced persons within the Council of Europe member states.
