FIFTH SECTION
CASE OF UKRAYINSKYY AND OTHERS v. UKRAINE
(Applications nos. 48751/19 and 41 others –
see appended list)
 
 
JUDGMENT
Art 34 • Undue interference with the exercise of the right of individual application of forty of the applicants through their questioning by prison officials about their applications and the compelling of some of them to give oral or written statements • No such interference in relation to the remaining two applicants who left the prison before the events giving rise to the complaint 
Art 3 (substantive) • Degrading treatment • Inadequate conditions of detention
Art 13 (+Art 3) • Lack of effective domestic remedies
 
Prepared by the Registry. Does not bind the Court. STRASBOURG
2 April 2026
 
This judgment will become final in the circumstances set out in Article 44 § 2 of the Convention. It may be subject to editorial revision. In the case of Ukrayinskyy and Others v. Ukraine,
The European Court of Human Rights (Fifth Section), sitting as a Chamber composed of:
 Kateřina Šimáčková, President,
 María Elósegui,
 Georgios A. Serghides,
 Gilberto Felici,
 Diana Sârcu,
 Mykola Gnatovskyy,
 Vahe Grigoryan, judges,
and Victor Soloveytchik, Section Registrar,
Having regard to:
the applications listed in the appendix;
the parties’ observations;
Having deliberated in private on 3 March 2026,
Delivers the following judgment, which was adopted on that date:
INTRODUCTION
1. The case concerns complaints about inadequate conditions of detention, the alleged hindrance by the prison authorities with the applicants’ effective exercise of their right of individual application under the Convention and the lack of any effective remedy in domestic law. The applicants relied on Articles 3, 8, 13 and 34 of the Convention. PROCEDURE
2. The case originated in the applications against Ukraine lodged with the Court under Article 34 of the Convention for the Protection of Human Rights and Fundamental Freedoms (“the Convention”) on 20 August 2019 by 43 Ukrainian nationals. One applicant subsequently died, and his application was struck out of the Court’s list of cases. The remaining 42 applicants (“the applicants”) and their corresponding applications are listed in the appended table. 3. The applicants were represented by four lawyers from the non-governmental organisation Kharkiv Human Rights Protection Group (“the KHRPG”, see appended table). 4. The Ukrainian Government (“the Government”) were represented by their Agents, Mr I. Lishchyna, succeeded by Ms M. Sokorenko, from the Ministry of Justice. 5. On 30 January 2020 the Government were given notice of the complaints concerning inadequate conditions of detention and the lack of any effective remedy in domestic law. The remainder of the applications was declared inadmissible pursuant to the procedure under Rule 54 § 3 of the Rules of Court. Both parties filed observations on the admissibility and merits. On 2 November 2020 additional complaints regarding alleged pressure to withdraw the applications were made by some of the applicants (see paragraph 21 below). 6. On 3 July 2024 the President of the Section decided, under Rule 54 § 2 (c) of the Rules of Court, to invite the parties to submit further written observations under Article 34 of the Convention regarding the alleged hindrance with the right of individual application. The Government and the applicants represented by Mr Tokarev, namely applicants nos. 26-28, 38 and 42, submitted their observations. THE FACTS
7. The applicants were, at the material time, detained in Zhovti Vody Correctional Colony no. 26 (“Zhovti Vody Prison”) in the Dnipropetrovsk Region. 8. The facts of the case, as submitted by the parties, may be summarised as follows. Conditions of the applicants’ detention
9. On 13 March 2019, allegedly at the request of the detainees, representatives of the KHRPG carried out a monitoring visit to Zhovti Vody Prison. During the visit, they met with inmates; inspected the accommodation units, canteen, and laundry and bathing facilities; took photographs; and collected written complaints. 10. During the visit, 84 detainees, including 11 of the applicants, prepared handwritten complaints addressed to the Prosecutor General, the Ministry of Justice and the Parliamentary Commissioner for Human Rights (“the Ombudsperson”), describing various shortcomings in the conditions of detention in the facility. 11. On 18 March 2019 the KHRPG published on its website a report concerning Zhovti Vody Prison[1]. Illustrated with numerous photographs, the report stated that the conditions of detention failed to meet established standards and caused serious harm to the prisoners’ health. The situation was described, inter alia, in the following terms:
“Living premises
... Almost all premises were in an unsanitary and neglected state. Dampness could be felt everywhere. Lighting in the dormitories was very poor, and in some areas entirely absent. To reach the living area on the ground floor, one had to pass through a completely dark corridor with stairs. Prisoners reported that electricity supply was usually limited to the period between nightfall and lights-out. In the living areas, iron beds with thin mattresses were placed in cramped conditions, as a result of which most of those interviewed complained of back pain. Severe overcrowding of cells was observed.
... The walls in the rooms on the second floor of the residential block were covered with fungus and mould, with many ceilings showing traces of past water leakage.
... Complaints were also received concerning an infestation of bedbugs and cockroaches in the premises. At the time of the visit, boiled drinking water was only available in one unit; in the others, only tap water was provided. According to the interviewees, the quality of the tap water was very poor: after one day of standing, rust sediment appeared, and in summer white worms bred in the water within a day. Prisoners stated that the night-time temperature in the living premises was 8-10 oC, dropping to 3-5 oC in winter ... The water supply pipes were rusty and leaking in places, resulting in periodic flooding in the establishment.
... Sanitary facilities
... They were not merely inadequate, but in a deplorable state. Washbasins had broken tiles and faulty taps. The stench was unbearable, making it impossible to enter the toilet rooms. Each unit contained between four and six toilets, and prisoners were forced to queue in order to relieve themselves. The toilets had no doors, and in some units the partitions were no taller than 50 centimetres. The sanitary equipment was in a state of disrepair.
... In some units, the shower rooms were flooded owing to leaking pipes. In each sector there was only one shower for the entire sector (approximately 50-60 people). According to the prisoners, even cold water was supplied to the prison for only two hours per day. As a result, inmates were compelled to fill tanks with water and wash themselves from them. Moreover, the stench in the toilets was aggravated by the absence of water in the flushing cisterns. Canteen
In the canteen, mould was visible on the ceiling and windowsills. The smell of damp was noticeable in the premises.
... Only five taps for handwashing were functional; the others were broken. Towels and soap were not available. During the visit, the canteen staff were unable to present sanitary certificates to the monitoring group, stating that they had been taken outside the prison for some form of inspection. Prisoners complained about shortages of food and poor quality of meals. Some of them stated that they bought ‘proper’ food at their own expense so that it could be prepared for them in the canteen. Bathhouse and laundry facilities
The bathhouse had been recently renovated and looked relatively decent compared with other premises seen ... At the time of the monitors’ visit, there was no water in the bathhouse, but the administration stated that the water was switched off after prisoners’ visits in order to prevent pipe bursts. Prisoners, however, insisted that they had not been able to use the bathhouse for over a month. The laundry was equipped with old Soviet-era washing machines and dryers, which were visibly rusty. On the day of the visit, prisoners were drying their clothes outside in +5 oC temperatures.
... Material and living conditions
Numerous complaints were received from prisoners concerning the lack of provision of clothing, footwear and personal hygiene items. Prisoners also complained that they were obliged to purchase light bulbs and carry out repairs in the units at their own expense ...”
12. On 25 March 2019 the KHRPG representatives carried out a second visit to the facility. They informed the prisoners of the possibility of applying to the Court and collected authority forms signed by the applicants, together with their personal data. 13. The applicants’ description of their conditions of detention, as submitted to the Court, essentially repeated the findings set out in the above-mentioned KHRPG report and was supported by numerous photographs taken in the facility. They complained, in particular, of mouldy and dirty cells infested with rodents and insects; recurring flooding owing to leaking pipes; the absence of hot water and limited access to cold water; the lack of potable water, toiletries and clothing; frequent power cuts; sanitary facilities in a state of disrepair, with toilets not ensuring privacy; insufficient laundry facilities; and poor-quality food served in unsanitary conditions. 14. According to the Government, during their first visit to the facility the KHRPG representatives also asked to inspect premises that had been sealed off and were not used for the accommodation of prisoners. They took photographs in those premises, as well as of some water of unknown origin contained in a five-litre plastic bottle handed to them by the prisoners. The monitors allegedly refused to collect tap water samples themselves in any of the accommodation units of the facility and declined to inspect the renovated unit no. 1. Following the visit, the above-mentioned photographs were included among others in the KHRPG report, thereby giving a misleading impression of the actual conditions of detention. 15. The Government further submitted that in 2019 extensive renovation works had been carried out in unit no. 1 and partial renovations in units nos. 2- 10. In some units the electrical and water supply systems had been repaired, while in others partition walls had been installed in toilet facilities. Twelve windows and three doors had been replaced and certain rooms had undergone cosmetic refurbishment. The interior walls had been treated with an anti-fungal agent and measures had been implemented to eradicate rats and insects in the canteen and storage areas. The facility, they maintained, was heated by its own solid-fuel boiler house, with the average temperature in the dormitories during the heating season not falling below +18 oC. The temperature of the water in the bathhouse used by prisoners met applicable standards, and inmates were provided with an opportunity to shower at least once a week, with compulsory replacement of linen. The facility was said to be fully supplied with cleaning products, and the drinking water available in the dormitories, canteen and medical unit complied with sanitary and microbiological requirements. 16. The Government also explained that, owing to arrears in the payment of utility services, the water supply was cut off daily from 11 a.m. to 4 p.m. and from 11 p.m. to 5.30 a.m. Furthermore, in order to reduce electricity consumption, a schedule had been introduced under which the electricity supply was disconnected from 8 or 9 a.m. until 2 or 3 p.m. 17. On 13 July 2020 the Ministry of Justice decided to close Zhovti Vody Prison. Following that decision, the applicants began to be transferred to other detention facilities. 18. On 31 October 2020 the Radio Svoboda website published an interview with the then Minister of Justice[2]. When asked by a journalist about “the Kharkiv Human Rights Protection Group reports that lawyers [were] contending that pressure [was] being put on prisoners in Zhovti Vody Prison because of a previously submitted application to the European Court of Human Rights,” the Minister replied:
“Well, no. Perhaps, of course, there is some pressure there. It would be strange if there were no pressure of one kind or another in a prison. The question is what it is motivated by. As for Zhovti Vody Prison – it seems to me that this is one of those prisons that we are closing down, maybe it has already been ‘frozen’. That is, in any case, it won’t exist for long, given that the detention conditions there are inadequate”. Questioning of the applicants concerning their complaints to the Court
19. The KHRPG report of 18 March 2019, mentioned above, also referred to possible future repercussions for the detainees in connection with the monitoring visit:
“... The prison administration, openly and without regard to the monitors’ presence, noted down the names of prisoners who approached the monitoring group, for the purpose of ‘further work with them’. According to the prisoners, representatives of the administration behaved sarcastically and threatened them as soon as the monitoring group left the premises, saying that the monitors would leave but the prisoners would have to remain. Prisoners expressed fears that, after the monitors’ departure, the administration would start to ‘put pressure on’ them. 20. On 11 March 2020, following the communication of the applications to the respondent Government, the administration of Zhovti Vody Prison organised meetings with the applicants to enquire about their complaints to the Court. Further similar interviews were carried out on 28 and 31 August 2020 in that facility, as well as in detention facilities in Dnipro, Kryvyi Rih and Zaporizhzhia, to which some of the applicants had been transferred by that time. In the course of those interviews, 4 applicants made written statements and 6 made oral statements declaring that they had no complaints regarding their conditions of detention, while 26 applicants declined to comment. The authorities drew up reports on the questioning for each of them (see appended table). According to some of those statements, the KHRPG representatives had allegedly handed the applicants blank forms, which they had signed without any intention of applying to the Court. No reports were prepared in respect of applicants nos. 37-40, while applicants nos. 41 and 42 had been released from detention in 2019, before the above-mentioned interviews took place. 21. In September and October 2020 the applicants’ representatives visited several of the applicants, who reported having been subjected to coercion by the prison authorities to withdraw their applications. Applicants nos. 4, 18, 23, 26 and 37 submitted handwritten statements citing insistent demands, deception, inducement and pressure to that end. On 2 November 2020 the representatives sent those statements to the Court, alleging a hindrance with the right of individual application. 22. Upon the Court’s transmission of the representatives’ letter to the Government, the prison authorities reportedly re-interviewed those five applicants on 31 December 2020 and 2 January 2021. According to the Government, applicants nos. 4 and 37 stated that they had signed the statements prepared by their representatives without reading them, while applicants nos. 18, 23 and 26 refused to comment. Applicant no. 37 also stated that the detention facility administration had not exerted any pressure on him to withdraw his application before the Court. No copies of those statements were submitted to the Court. Loss of contact with the applicants
23. After the Court had given notice to the Government of the applicants’ complaint under Article 34 of the Convention, on 13 October 2024 Ms Ovdiyenko, a lawyer representing applicants nos. 4, 10 and 29-40 informed the Court that she was no longer able to act as a representative in any of the applications owing to restrictions arising from her new professional position. Her letter was forwarded to the other representatives in the case with a view to a possible substitution, but none of them took any action. Accordingly, no observations regarding Article 34 were submitted on behalf of those applicants. 24. Likewise, no observations on the Article 34 issue were received from two other lawyers: Mr Revyakin, representing applicants nos. 1, 2, 5-7, 11-18 and 37, and Mr Glushchenko, representing applicants nos. 3, 8, 9, 19-25 and 41, despite their having downloaded the request for observations through the Court’s Electronic Communications Service (eComms) on 4 November 2024. A warning letter sent by registered post to Mr Revyakin was returned marked “received under a power of attorney”, whereas the letter addressed to Mr Glushchenko came back unclaimed. 25. On 30 April 2025 the director of the KHRPG informed the Court that the three above-mentioned lawyers had ceased to cooperate with the organisation and that, as regards Mr Revyakin, even his whereabouts were unknown owing to the ongoing war. The KHRPG accordingly asked the Court to continue the examination of the case in view of the initial joint preparation of the applications and on the basis of the observations submitted by the remaining fourth representative, Mr Tokarev. 26. No other means of establishing contact with the 37 applicants represented by the above-mentioned three lawyers were available to the Court, as they had all only indicated the postal address of Zhovti Vody Prison in their application forms, which had never been updated. All of them had been released or transferred from that facility by the end of 2020. RELEVANT DOMESTIC REPORTS AND OTHER MATERIAL
27. In the 2017 annual report, the Ombudsperson noted a number of recurrent shortcomings identified during visits to Zhovti Vody Prison:
“Monitoring visits repeatedly confirmed violations of national requirements concerning the minimum living space for prisoners and remand detainees.
... In many of the institutions visited, ceilings bore stains indicating leakage from sewage pipes. Sanitary equipment was in most cases outdated, and flushing cisterns in toilets were absent. In some punishment cells of Zhovti Vody Correctional Colony (no. 26), polyethylene film had been stretched over the windows instead of glass.
... No supply-and-exhaust ventilation was installed in those cells, and in all the institutions visited prisoners were unable to open the windowpanes themselves while held in disciplinary cells in order to access fresh air. In one of the enhanced disciplinary unit cells of Zhovti Vody Correctional Colony (no. 26), there was no access to fresh air at all.
... Exercise yards in certain institutions required improvement, in particular by equipping them with properly sized shelters to protect against precipitation.
... There was an insufficient level of natural or artificial lighting.
... The dishes in which food was delivered to certain areas of the institutions were often dirty and sometimes even rusty.”
28. The report also highlighted tensions between the prison administration and the inmates:
“During interviews with prisoners in Zhovti Vody Correctional Colony (no. 26), repeated complaints were received concerning biased treatment by certain officials of the institution and the creation by the administration of artificial conditions leading to conflicts between prisoners.
...
... the grounds for keeping prisoners in the [enhanced disciplinary] units had in fact not been reviewed, as a result of which some prisoners remained in such units without justification.
...
... prisoners reported abuse by representatives of the administration in applying disciplinary measures.”
29. In a press release published on 23 July 2020 following a subsequent monitoring visit to Zhovti Vody Prison, the Ombudsperson’s office reported that the facility’s administration had failed to remedy most of the violations identified during the previous visit:
“... the monitoring group found several stigmatised prisoners who were living in separate premises not adapted for that purpose and who were not provided with bed linen. The staff of the institution at first acknowledged, and later attempted to conceal, the facts of the inadequate conditions of detention of these persons. The monitors further established that, owing to the institution’s significant arrears for utility services, the water supply and electricity in the prisoners’ dormitories were being cut off. In addition, numerous violations were revealed in the organisation of food provision for prisoners. Thus, with more than 660 prisoners, the canteen had only about 80-100 plates, all in extremely worn condition. New plates were available in storage but were not being used.”
THE LAW
         JOINDER OF THE APPLICATIONS
30. Having regard to the similar subject matter of the applications, the Court finds it appropriate to examine them jointly in a single judgment. PRELIMINARY ISSUE: CONTINUED EXAMINATION OF THE APPLICATIONS (Article 37 § 1 (a) OF THE CONVENTION)
31. The Court notes at the outset the loss of contact with 37 of the 42 applicants, which calls for an assessment of the need to continue the examination of their applications in view of Article 37 of the Convention. The relevant parts of this provision read as follows:
“1. The Court may at any stage of the proceedings decide to strike an application out of its list of cases where the circumstances lead to the conclusion that
(a)  the applicant does not intend to pursue his application; ... However, the Court shall continue the examination of the application if respect for human rights as defined in the Convention and the Protocols thereto so requires.”
32. The circumstances falling within the scope of Article 37 § 1 (a) include not only an applicant’s express withdrawal of the application, but also instances where he or she fails to submit observations (see, for example, Baryshev v. Ukraine (dec.), no. 17363/06, 14 September 2010), to appoint a representative (see Rozgon v. Ukraine (dec.), no. 26122/08, 27 April 2010) or to maintain contact with the Court throughout the proceedings (see Soproun v. Ukraine (dec.), no. 39402/02, 16 March 2010). Such contact, specifically, is essential both in order to learn more about an applicant’s particular situation and to confirm his or her continuing interest in pursuing the application (see, mutatis mutandis, V.M. and Others v. Belgium (striking out) [GC], no. 60125/11, §§ 35-40, 17 November 2016). 33. In the present case, three of the four representatives did not submit comments on the Government’s observations and effectively ceased to act in the proceedings. Ms Ovdiyenko withdrew from the case of her own motion, while Mr Revyakin and Mr Glushchenko failed to respond to the Court’s correspondence. Nor did they inform the Court of any substitution or provide any other means of communication with the applicants. The applicants themselves, albeit bearing the consequences of their representatives’ procedural conduct, have not communicated with the Registry since. In these circumstances, the Court considers that the applicants represented by Ms Ovdiyenko (until 13 October 2024), Mr Revyakin and Mr Glushchenko may be regarded as no longer wishing to pursue their applications within the meaning of Article 37 § 1 (a) of the Convention. 34. That being said, the Court must also ascertain whether there are any circumstances relating to respect for human rights as defined in the Convention and its Protocols which require the continued examination of the case (Article 37 § 1 in fine). Such circumstances may be found to exist where such an examination would contribute to the elucidation, safeguarding or development of the standards of protection under the Convention (see, for example, H.P. v. Denmark (dec.), no. 55607/09, § 85, 13 December 2016, and, a contrario, Konstantin Markin v. Russia [GC], no. 30078/06, § 90, ECHR 2012 (extracts)). 35. There have, however, been very few instances in which the Convention institutions have relied on this safeguard in the context of Article 37 § 1 (a), that is, where an applicant was found not to intend to pursue his or her application. For example, where a formal request for withdrawal had been submitted, the Court continued its examination when the withdrawal appeared ambiguous (see Sidjimov v. Bulgaria, no. 55057/00, §§ 25-31, 27 January 2005), when the applicant’s mental state had to be taken into account (see Tehrani and Others v. Turkey, nos. 32940/08 and 2 others, §§ 53-57, 13 April 2010) or when intimidation of the applicant or members of the applicant’s family by the authorities had been reported (see Kurt v. Turkey, no. 24276/94, Commission decision of 22 May 1995, Decisions and Reports 81-A, p. 112). The alleged loss of contact between the applicants and their representative did not prevent the further examination of a case whose impact went beyond the individual situation of the applicants (see N.D. and N.T. v. Spain [GC], nos. 8675/15 and 8697/15, §§ 75-79, 13 February 2020, concerning migrants attempting to enter a Contracting State in an unauthorised manner). 36. By contrast, in Cannavacciuolo and Others v. Italy (nos. 51567/14 and 3 others, §§ 187-92, 30 January 2025), the complaints of an applicant with whom contact had been lost, although raising an important question of general interest, were analogous to those pursued by the remaining applicants. The Court was therefore able to determine the issue on the merits without that particular applicant contributing any new element in that connection. 37. Turning to the circumstances of the present case, the Court observes two factors militating in favour of continuing its examination. 38. Firstly, as in N.D. and N.T. v. Spain (cited above), the case has a potential impact going beyond the individual situation of the applicants, as it touches upon the very essence of the system of individual petition established under Article 34 of the Convention, namely the right of an individual to present and pursue a complaint before the Court effectively. In this connection, the applicants have made an arguable allegation of repeated attempts by prison officials in various detention facilities across the country to dissuade them from pursuing the Convention remedy. This is of further importance in the context of the respondent State, given that the alleged pressure occurred after the communication to the Government of the applicants’ complaints concerning inadequate conditions of detention – a structural problem in Ukraine affecting thousands of actual and potential applicants (see Sukachov v. Ukraine, no. 14057/17, § 137, 30 January 2020). 39. The second factor weighing against striking out these 37 applications is the exceptional combination of their particular circumstances: the alleged pressure exerted on the applicants, which may have deterred them from pursuing the Convention remedy; the variations in the circumstances in which such pressure was allegedly exerted in respect of different applicants, and the importance of examining all types of pressure; Russia’s full-scale invasion of Ukraine, which has undoubtedly complicated communication with the Court; and the fact that the applicants had already submitted observations before the case was recommunicated under Article 34 (see paragraph 5 above). This consideration effectively precludes the Court from following the approach adopted in Cannavacciuolo and Others (cited above; see paragraph 36), that is, from limiting its examination to the remaining five applicants, despite the similar factual context and analogous legal issues raised in all 42 applications. 40. There are therefore special circumstances relating to respect for human rights as defined in the Convention and the Protocols thereto which require the examination of the applications lodged on behalf of the applicants by Ms Ovdiyenko, Mr Revyakin and Mr Glushchenko to continue. ALLEGED HINDRANCE OF THE RIGHT OF INDIVIDUAL PETITION UNDER ARTICLE 34 OF THE CONVENTION
41. The applicants complained that they had been subjected to pressure by the prison authorities aimed at inducing them to withdraw or undermine their complaints to the Court. They alleged that, as a result, the respondent State had hindered the effective exercise of their right of individual application, as provided by Article 34 of the Convention, which reads as follows:
“The Court may receive applications from any person, non-governmental organisation or group of individuals claiming to be the victim of a violation by one of the High Contracting Parties of the rights set forth in the Convention or the Protocols thereto. The High Contracting Parties undertake not to hinder in any way the effective exercise of this right.”
   The parties’ submissions
42. The applicants submitted that their questioning had been directly triggered by the Government’s receipt of the Court’s notification of the present applications, initiated solely by detention facility administrations without any request from the applicants, and limited only to those prisoners who had applied to the Court. The questioning had aimed to force the applicants to withdraw their complaints to the Court by making insistent demands, providing misleading information and threatening disciplinary action, including placement in a disciplinary cell. The statements attached to the Government’s observations had therefore been obtained in a clearly involuntary manner, their content contradicting the handwritten statements submitted through the applicants’ representatives and providing no reasonable explanation as to why most applicants had suddenly withdrawn their complaints concerning the conditions of their detention. Lastly, the applicants noted that despite the pressure none of them had reported that they had not signed an authority form for representation before the Court. 43. The Government in their initial observations contested the authenticity of the applications and the validity of the applicants’ representation by the KHRPG lawyers, characterising their activity as an abusive practice. In particular, they referred to the reports drawn up after questioning the prisoners, which indicated that the applicants had merely signed blank forms and had not intended to apply to the Court (see paragraph 20 above). The Government denied that any pressure had been exerted and stated that their Agent had never instructed the administrations of the detention facilities to question the applicants. 44. Following the formal notification of the additional complaint under Article 34 of the Convention, the Government no longer objected to the validity of the applicants’ representation but submitted that the applications lacked sufficient detail, specificity and individualisation. They maintained that the administrations of the detention facilities had in fact met with the applicants in order to clarify and address their complaints under the Convention. The Court’s assessment     General principles

45. The relevant general principles concerning the State’s obligation to refrain from any act or omission that may hinder the effective exercise of the right of individual application under Article 34 of the Convention have been summarised in Shirkhanyan v. Armenia (no. 54547/16, §§ 191-94, 22 February 2022). This obligation comprises both a negative undertaking to abstain from any arbitrary interference and a positive duty to furnish all necessary facilities to enable the proper and effective examination of applications (ibid.). 46. When assessing whether a Contracting State has complied with the negative aspect of its obligation under Article 34, the Court takes into account the nature of the alleged interference (see, as regards questioning applicants, Davydov and Others v. Ukraine, nos. 17674/02 and 39081/02, § 337, 1 July 2010, and Sergey Antonov v. Ukraine, no. 40512/13, §§ 105‑10, 22 October 2015), its purpose (see Vladimir Sokolov v. Russia, no. 31242/05, § 81, 29 March 2011) and an applicant’s vulnerability (see Cotleţ v. Romania, no. 38565/97, § 71, 3 June 2003; Knyazev v. Russia, no. 25948/05, § 116, 8 November 2007; and Bogdan Shevchuk v. Ukraine, no. 55737/16, § 49, 24 April 2025). Whether or not contact between the authorities and an applicant are tantamount to unacceptable practices from the standpoint of Article 34 must be determined in the light of the particular circumstances of the case (see Oferta Plus SRL v. Moldova, no. 14385/04, § 134, 19 December 2006). Application of the above principles to the present case
47.

Outcome for Article 34: violation