ECtHR strikes out new batch of Azerbaijani cases:
Unilateral declarations undermine justice
On 25 September 2025, the European Court of Human Rights (ECtHR) issued another decision in a series of cases against Azerbaijan concerning politically motivated administrative detentions. The Court joined six applications, including Guliyev v. Azerbaijan (no. 6261/24), three of the applicants being prisoners in politically motivated criminal cases (Ilhamiz Guliyev, Mohyaddin Orujov and Kanan Zeynalov), and struck them out of its list after accepting unilateral declarations from the Azerbaijani Government.
The applicants had complained under Article 6 of the Convention that they were denied fair trials in administrative offence proceedings, a practice that has long been criticised by the Court. Previous judgments such as Gafgaz Mammadov v. Azerbaijan (2015) and Huseynli and Others v. Azerbaijan (2016) have already established a consistent pattern: administrative detentions are widely used against political opponents, civil society actors, and critical voices, with no meaningful judicial safeguards.
In its unilateral declaration, the Azerbaijani Government acknowledged violations of the applicants’ rights and offered compensation of 900 EUR to each applicant, plus 225 EUR for legal fees. The Court accepted these terms, finding that “it is no longer justified to continue the examination of the applications” and that respect for human rights did not require further consideration of the merits.
A hollow remedy
On paper, the unilateral declaration procedure allows governments to resolve repetitive cases without full proceedings. In practice, however, it has become the standard way Azerbaijan avoids accountability. The Government routinely offers low, symbolic sums without addressing the underlying systemic issues. The ECtHR accepts these terms, despite repeated objections from applicants and their lawyers.
The outcome is predictable: a human rights defender who spends 30 days in an administrative detention facility – often in degrading conditions and sometimes ill-treated – receives about 1,000 EUR in compensation two years later. For election-related violations, the “price” is around 4,000 EUR; for NGO non-registration cases, about 2,000 EUR. These figures have become a tariff system of sorts, replacing real accountability and full restitution of rights with financial settlements.
Victims in Azerbaijan underline that these awards are not satisfactory, and that the Government does not implement wider measures to restore rights. Despite the Court’s references to good faith, there is no evidence of structural reform. Moreover, since Azerbaijan was excluded from the Parliamentary Assembly of the Council of Europe (PACE), the country has not paid compensation in any of these cases.
Furthermore, there is no improvement concerning implementation of cases supervised by the Committee of Ministers (especially in politically motivated criminal cases). Still Azerbaijan catches first place in non-implementation.
Currently, according to the Council of Europe, the Azerbaijani government has resolved the problem in only 192 cases out of a total of 535 cases (it should be noted that most of these cases are repetitive cases and many cover other issues, for example, cases related to the illegal settlement of internally displaced persons). This accounts for 36% of the total cases. However, the execution status of 343 cases is active and these decisions have not been implemented. This accounts for 64% of the total statistics. These statistics make Azerbaijan the leading country in non-implementation of ECHR decisions
The Court’s restrictive approach
The ECtHR’s acceptance of unilateral declarations reflects its increasingly restrictive approach to repetitive Azerbaijani cases. Rather than issuing fresh judgments that would underline the seriousness of ongoing violations, the Court opts for procedural efficiency. This weakens its role as an effective remedy. Applicants often see the Court not as a path to justice, but as a predictable cash-out process.
The Court has emphasised that it may restore applications to its list if governments fail to comply with their declarations. Yet in practice, very few cases are reopened, and no systematic monitoring ensures that the root causes of violations are addressed.
Loss of effectiveness
The consequence is clear: for Azerbaijanis subjected to arbitrary arrests and sham administrative proceedings, the ECtHR no longer functions as an effective remedy. It offers limited financial redress without meaningful recognition of the harm suffered, and without pressure for systemic change.
Vatslav Havel Guliyev v. Azerbaijan decision once again highlights the paradox facing victims of politically motivated repression in Azerbaijan: the Court continues to acknowledge violations, but it does so in a way that normalises them. For the Azerbaijani Government, the cost of repression is little more than a budget line. For victims, justice remains out of reach.
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