This judgment concerns several applications against Russia regarding disproportionate measures taken against solo demonstrators. The applicants complained about the termination of their demonstrations, arrests, and convictions for administrative offenses, arguing these measures violated their freedom of expression. The European Court of Human Rights (ECtHR) found that these measures were not “necessary in a democratic society” and thus violated Article 10 of the Convention. Additionally, some applicants raised other complaints related to issues such as unlawful detention and lack of impartiality in administrative proceedings, which the Court also found to be violations based on its well-established case-law. The Court decided that a finding of a violation was sufficient just satisfaction for two applicants, while the remaining applicants were awarded specific sums for pecuniary and non-pecuniary damage.
The structure of the decision includes sections on procedure, facts, and the law. The “Law” section addresses the joinder of the applications, the Court’s jurisdiction, and the alleged violations of Article 10 of the Convention. It references previous leading cases, such as *Novikova and Others v. Russia*, to support its findings. The decision also addresses other alleged violations under well-established case-law and considers remaining complaints. Finally, it outlines the application of Article 41 of the Convention regarding just satisfaction. There are no indications of changes compared to previous versions, as the judgment focuses on applying existing principles to the specific facts of the cases.
The most important provisions of this decision are those confirming that disproportionate measures against solo demonstrators violate Article 10 of the Convention. The judgment reinforces the importance of freedom of expression and peaceful assembly, even for solo demonstrations. Additionally, the findings of violations related to unlawful detention, lack of impartiality in administrative proceedings, and delayed review of convictions highlight critical procedural safeguards that must be respected. The decision also clarifies the Court’s approach to just satisfaction, providing specific guidance on when a finding of a violation is sufficient and when monetary compensation is warranted. **** This decision may be important for Ukrainians, as it highlights the importance of freedom of expression and peaceful assembly, even for solo demonstrations.
