Razvyazkin v. Russia

(Prisons – Disciplinary proceedings)
European Court of Human Rights
3 July 2012


The applicant, Mr. Razvyazkin, was serving his prison sentence. He was repeatedly disciplined for breaching colony rules, including by placement in punishment cells and solitary confinement cells. 


Mr. Razvyazkin complained under Article 3 of the Convention about the conditions of his almost uninterrupted solitary confinement for almost 3 years. 

Court's ruling

The Court noted that the prohibition of contact with other prisoners for security, disciplinary or protective reasons does not in itself amount to inhuman treatment or punishment. The Court stressed that substantive reasons must be given when a protracted period of solitary confinement is extended. Such decision must reveal that the authorities have carried out a reassessment that takes into account any changes in the prisoner’s circumstances, situation or behavior. The statement of reasons will need to be increasingly detailed and compelling the more time goes by.

In the particular case the Court observed that the domestic authorities had failed to provide any substantive reasons for the necessity such prolonged placement in solitary confinement. There was also no objective assessment whether repeated placement in solitary confinement fulfilled its goals. Therefore the Court found that the applicant’s placement in solitary confinement amounted to inhuman and degrading treatment.

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Last updated 08/11/2023