The case of *Federico and Raddi v. Italy* concerns the death of a prisoner, A.R., who suffered from significant and progressive weight loss while detained in Turin Prison. Despite repeated alerts from the National Guarantor of the Rights of People Detained and the prisoner’s own complaints, the prison authorities failed to conduct timely diagnostic investigations, dismissing the weight loss as a “manipulative strategy.” The prisoner’s health deteriorated to the point of requiring a wheelchair, and he eventually died of septic shock following a pulmonary infection. The Court found that the medical care provided was neither adequate nor timely, and that the authorities failed to take the necessary steps to protect the prisoner’s life and physical integrity. Consequently, the Court ruled that Italy violated both the substantive and procedural aspects of Articles 2 (right to life) and 3 (prohibition of inhuman or degrading treatment) of the Convention. ****: This judgment reinforces the established jurisprudence regarding the state’s positive obligations toward detainees, which is highly relevant for the protection of human rights in the context of the ongoing war in Ukraine, particularly concerning the treatment of prisoners of war and civilian detainees.
### Structure and Provisions
The judgment follows the standard structure of the European Court of Human Rights:
1. **Admissibility:** The Court dismissed the Government’s objection regarding the non-exhaustion of domestic remedies, affirming that the applicants had sufficiently pursued the available criminal investigation channels.
2. **Merits:** The Court analyzed the state’s positive obligations under Articles 2 and 3. It assessed whether the authorities acted in good faith and in a timely manner to prevent the fatal outcome.
3. **Just Satisfaction:** The Court awarded pecuniary damages for funeral costs and non-pecuniary damages for the suffering caused by the state’s failure.
Compared to previous versions of similar cases, this judgment emphasizes that a prisoner’s lack of cooperation or refusal of treatment does not absolve the state of its duty to investigate underlying medical causes, especially when a detainee’s condition is visibly deteriorating.
### Main Provisions for Practical Use
* **Positive Obligations:** The decision clarifies that the state’s duty to preserve the health of prisoners is absolute. Even if authorities suspect a prisoner is “manipulating” their condition (e.g., refusing food), they are legally required to ascertain the true medical reasons through objective clinical practice rather than relying on subjective assumptions.
* **Systemic Failures:** The Court highlighted that “lack of capacity” (e.g., waiting for a hospital bed) does not excuse the state from its obligation to provide urgent care. If a prisoner’s condition is critical, the state must prioritize access to specialized medical facilities.
* **Evidence of Negligence:** The Court relied heavily on the findings of independent medical experts who identified “undue delays” and “lack of coordination” among healthcare staff. This underscores the importance of obtaining independent expert testimony when challenging the adequacy of prison medical care.
* **Relevance to Ukraine:** The Court explicitly cited *Karpylenko v. Ukraine* and *Salakhov and Islyamova v. Ukraine*, confirming that the standards applied here are consistent with the Court’s expectations for the Ukrainian authorities in managing the health of those in state custody. This serves as a critical benchmark for legal practitioners representing victims of medical neglect in detention settings.
