On 3 February 2026, the European Court of Human Rights delivered its judgment in Navalnyy v. Russia (no. 4) (applications nos. 4743/21 and 37083/21), finding multiple violations of the European Convention on Human Rights in connection with Aleksey Navalnyy’s detention and imprisonment in Russia. A member of the ROLE team represented Mr Navalnyy in the proceedings before the Court.
The Court found violations of Article 2 (right to life), Article 3 (prohibition of inhuman or degrading treatment), Article 5.1 (right to liberty and security), and Article 34 (right of individual application).
In particular, the Court held that Mr Navalnyy’s imprisonment was unlawful, as it was based on a 2014 conviction which the Court had previously found to have resulted from proceedings amounting to a “flagrant denial of justice”. The Court further found that the Russian authorities had failed to adequately assess the real and immediate risks to Mr Navalnyy’s life and had taken no appropriate preventive measures, despite his near-fatal poisoning in 2020 and the concerns he had raised regarding his safety.
The Court also found that the conditions of Mr Navalnyy’s detention amounted cumulatively to inhuman and degrading treatment, noting, among other things, arbitrary sleep deprivation over a period of 39 days and the shaving of his head without a legal basis or valid justification.
Finally, the Court found a violation of Article 34, holding that Russia had failed to comply with the Court’s interim measure of 16 February 2021 indicating Mr Navalnyy’s immediate release.
The judgment is significant for the Court’s findings concerning the State’s positive obligations to protect the life and dignity of persons in detention, the requirement of lawfulness and foreseeability in deprivation of liberty, and the binding nature of interim measures indicated by the Court.
