KHAKIM A OSTATNÍ proti Rusku

THIRD SECTION

CASE OF KHAKIM AND OTHERS v. RUSSIA

(Applications nos. 66883/14 and 8 others –

see appended list)

JUDGMENT

STRASBOURG

22 January 2026

This judgment is final but it may be subject to editorial revision.

In the case of Khakim and Others v. Russia,

The European Court of Human Rights (Third Section), sitting as a Committee composed of:

Úna Ní Raifeartaigh, President,
Mateja Đurović,
Vasilka Sancin, judges,

and Viktoriya Maradudina, Acting Deputy Section Registrar,

Having deliberated in private on 18 December 2025,

Delivers the following judgment, which was adopted on that date:

PROCEDURE

1. The case originated in applications against Russia lodged with the Court under Article 34 of the Convention for the Protection of Human Rights and Fundamental Freedoms (“the Convention”) on the various dates indicated in the appended table.

2. The Russian Government (“the Government”) were given notice of the applications.

THE FACTS

3. The list of applicants and the relevant details of the applications are set out in the appended table.

4. The applicants complained of the disproportionate measures against solo demonstrators. They also raised other complaints under the provisions of the Convention.

THE LAW

1. JOINDER OF THE APPLICATIONS

5. Having regard to the similar subject matter of the applications, the Court finds it appropriate to examine them jointly in a single judgment.

2. Jurisdiction

6. The Court observes that the facts giving rise to the alleged violations of the Convention occurred prior to 16 September 2022, the date on which the Russian Federation ceased to be a party to the Convention. The Court therefore decides that it has jurisdiction to examine the present applications (see Fedotova and Others v. Russia [GC], nos. 40792/10 and 2 others, §§ 68‑73, 17 January 2023).

3. ALLEGED VIOLATION OF ARTICLE 10 of the Convention

7. The applicants complained principally of the disproportionate measures against solo demonstrators. They relied, expressly or in substance, on Article 10 of the Convention.

8. In the leading cases of Novikova and Others v. Russia, nos. 25501/07 and 4 others, 26 April 2016 and Lashmankin and Others v. Russia, nos. 57818/09 and 14 others, 7 February 2017, the Court already found a violation in respect of issues similar to those in the present case (see further, in so far as relevant, Nemytov and Others v. Russia (nos. 1257/21 and 2 others, §§ 136-151, 27 May 2025).

9. Having examined all the material submitted to it, and having taken into account the issue of compliance with the six-month time-limit under Article 35 § 1 of the Convention (see Saakashvili v. Georgia (dec.), nos. 6232/20 and 22394/20, §§ 46-59, 1 March 2022, in which the Court addressed the COVID‑related extension of the period in question), the Court has not found any fact or argument capable of persuading it to reach a different conclusion on the admissibility and merits of these complaints. Having regard to its case-law on the subject, the Court considers that in the instant case the interferences with the applicants’ freedom of expression were not “necessary in a democratic society”.

10. These complaints are therefore admissible and disclose a breach of Article 10 of the Convention.

4. OTHER ALLEGED VIOLATIONS UNDER WELL-ESTABLISHED CASE-LAW

11. The applicants submitted other complaints which also raised issues under the Convention, given the relevant well-established case-law of the Court (see appended table). These complaints are not manifestly ill-founded within the meaning of Article 35 § 3 (a) of the Convention, nor are they inadmissible on any other ground. Accordingly, they must be declared admissible. Having examined all the material before it, the Court concludes that they also disclose violations of the Convention in the light of its findings in Butkevich v. Russia, no. 5865/07, §§ 63-65, 13 February 2018, Tsvetkova and Others v. Russia, nos. 54381/08 and 5 others, §§ 115-31, 10 April 2018, and Korneyeva v. Russia, no. 72051/17, §§ 34-36, 8 October 2019, as to various aspects of unlawful deprivation of liberty of organisers or participants of public assemblies; and Karelin v. Russia, no. 926/08, §§ 58-85, 20 September 2016, concerning the absence of a prosecuting party in the proceedings under the Code of Administrative Offences.

5. Remaining complaints

12. The applicant in application no. 47330/20 raised complaints under Articles 5, 6, 11 and Article 4 of Protocol No.7 in respect of her conviction in two sets of the CAO proceedings in connection with her participation in a rally of 16 December 2019 against construction of a combustion plant in Tatarstan. The two final judgments in her case were issued on 22 January 2020 by the Supreme Court of Tatarstan. She lodged the complaints on 7 October 2020. The Court considers that, in the light of all the material in its possession and in so far as the matters complained of are within its competence, these complaints were lodged out of time and must be rejected in accordance with Article 35 §§ 1 and 4 of the Convention (see Masse v. France (dec.), no. 47506/20, 25 March 2025).

13. Lastly, some applicants raised further additional complaints under various Convention provisions. In view of the findings in paragraphs 9-11 above, the Court considers that there is no need to deal separately with these remaining complaints.

6. APPLICATION OF ARTICLE 41 OF THE CONVENTION

14. Regard being had to the documents in its possession and to its case‑law (see, mutatis mutandis, Navalnyy and Others v. Russia [Committee], nos. 5809/17 and 14 others, § 22, 4 October 2022), the Court considers it reasonable to award the sums indicated in the appended table. It further decides to dismiss the remainder of the applicants’ claims for just satisfaction in application no. 66883/14, in which such claims were requested and submitted.

FOR THESE REASONS, THE COURT, UNANIMOUSLY,

1. Decides to join the applications;
2. Holds that it has jurisdiction to deal with these applications as they relate to facts that took place before 16 September 2022;
3. Declares the complaints under Article 10 concerning disproportionate measures against solo demonstrators and the other complaints under the well-established case-law of the Court, as set out in the appended table, admissible, and the complaints under Articles 5, 6 and 11 of the Convention and Article 4 of Protocol No.7 in application no. 47330/20 concerning the applicant’s prosecution in the administrative-offence proceedings in connection with the rally of 16 December 2020 inadmissible, and decides that there is no need to examine separately the remaining complaints of the applicants;
4. Holds that these applications disclose a breach of Article 10 of the Convention concerning the disproportionate measures against solo demonstrators;
5. Holds that there has been a violation of the Convention as regards the other complaints raised under the well-established case-law of the Court (see appended table);
6. Holds

(a) that the respondent State is to pay the applicants, within three months, the amounts indicated in the appended table, to be converted into the currency of the respondent State at the rate applicable at the date of settlement;

(b) that from the expiry of the above-mentioned three months until settlement simple interest shall be payable on the above amounts at a rate equal to the marginal lending rate of the European Central Bank during the default period plus three percentage points;

7. Dismisses the remainder of the applicants’ claims for just satisfaction in application no. 66883/14.

Done in English, and notified in writing on 22 January 2026, pursuant to Rule 77 §§ 2 and 3 of the Rules of Court.

Viktoriya Maradudina Úna Ní Raifeartaigh

Acting Deputy Registrar President

APPENDIX

List of applications raising complaints under Article 10 of the Convention

(disproportionate measures against solo demonstrators)

[1] Plus any tax that may be chargeable to the applicants.