Rule 9.2 Communication on the Muradova v. Azerbaijan case (22684/05)

Rule 9.2 Communication Muradova Azerbaijan was submitted by Free Voices Collective to the Committee of Ministers of the Council of Europe on 2 December 2025, ahead of the Committee’s 1553rd Human Rights (DH) meeting scheduled for March 2026. 

The communication concerns the continued non-execution of the European Court of Human Rights’ judgment in Muradova v. Azerbaijan, which found violations of Article 3 (prohibition of torture and ill-treatment) and Article 13 (right to an effective remedy) of the European Convention on Human Rights. It highlights the Azerbaijani authorities’ persistent failure for more than 16 years to ensure an effective investigation into police violence and to adopt structural reforms capable of preventing similar violations. 

Rule 9.2 Communication Muradova Azerbaijan submission recalls that the European Court found that Ms Muradova was subjected to police violence during a public demonstration, resulting in severe injury and loss of vision in one eye, and that the authorities failed to carry out a prompt, independent, and effective investigation into her ill-treatment. Despite long-standing supervision by the Committee of Ministers, no meaningful individual or general measures have been implemented to remedy these violations. 

Key concerns raised in the submission

The Rule 9.2 communication stresses that:

• No effective investigation has been reopened into the police violence suffered by Ms Muradova, despite the Court’s clear findings;
• The authorities rely on the destruction of case files to justify inaction, in direct contradiction with the Court’s Article 3 jurisprudence;
• Judicial oversight of prosecutorial inaction remains purely formal, preventing accountability for ill-treatment;
• The prosecution service remains structurally dependent on the executive, undermining independence;
• The forensic examination system lacks independence, making it impossible for victims to challenge state-produced evidence;
• Torture and ill-treatment remain systemic and widespread, as confirmed by the CPT, the UN Committee Against Torture, and recent reporting on political prisoners and detained journalists;
• The ongoing crackdown on independent media and civil society further undermines the possibility of effective investigations and remedies under Articles 3 and 13.

Free Voices Collective’s recommendations to the Committee of Ministers

Individual measures

Free Voices Collective calls on the Committee of Ministers to urge the Azerbaijani authorities to:

• Reopen and conduct a prompt, independent, impartial and effective investigation into the police violence against Ms Muradova;
• Reconstruct the case file using available medical records, witness testimony, media materials and independent forensic expertise;
• Guarantee Ms Muradova’s full victim status, including access to the case file and effective judicial review;
• Ensure remedies go beyond financial compensation, including acknowledgement of wrongdoing and accountability for perpetrators. 

General measures

Rule 9.2 Communication Muradova Azerbaijan submission further calls on the authorities to:

• Secure genuine independence of the prosecution service, in line with Venice Commission and GRECO recommendations;
• Establish effective safeguards against torture, including independent complaints mechanisms and mandatory audio-visual recording of interrogations;
• Reform the forensic examination system to allow genuinely independent expertise;
• End confession-based criminal justice practices by enforcing strict exclusionary rules for coerced or uncounselled statements;
• Ensure an enabling environment for journalists and human rights defenders, whose work is essential for preventing and documenting ill-treatment.
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Given the long-standing and aggravated non-execution of the Muradova judgment, the communication urges the Committee of Ministers to maintain enhanced supervision and to consider the preparation of an interim resolution should no tangible progress be achieved by the next examination

Click here to read the submission: Rule 9.2 Communication on the Muradova v. Azerbaijan case (22684/05)

See our previous submission on the Namat Aliyev group of cases v. Azerbaijan.