BAZHENOV AND OTHERS v. RUSSIA AND UKRAINE - 20092/18 (Striking out applications - Art 37 s 1 (a) - Absence of intention to pursue parts of the applications with complaints against Ukraine : Preliminary objection partially joined to merits and dismissed : Fourth Section) [2026] ECHR 147 (16 July 2026)

Executive summary

The European Court of Human Rights struck out the parts of the applications against Ukraine under Article 37 § 1 (a), finding an absence of intention to pursue those complaints and no special circumstances requiring continued examination. It also dealt with complaints arising from the Russian authorities’ cancellation of land titles in Sevastopol, Crimea, including issues under Article 1 of Protocol No. 1 and Article 6 § 1.

Key points

• Applicants: multiple individuals in applications against Russia and Ukraine; the case concerned land in Sevastopol, Crimea.
• Holding on Ukraine: complaints against Ukraine were struck out because the Court found no intention to pursue those parts and no special human-rights reason to continue.
• Property reasoning: the Court linked the case to Ukraine v. Russia (re Crimea) and addressed Russian-law title cancellations in Crimea.
• Article 1 P1: the Court recorded findings on possessions, deprivation of property, and whether the interference was in accordance with the law.
• Article 6 § 1: it addressed whether Russian ‘courts’ in Crimea were tribunals established by law.
• Sanctions/export-control angle: the decision is about the legal consequences of Russia’s post-annexation exercise of authority in Crimea, relevant to territorial-risk, asset-title, and occupation-compliance analysis.

Why it matters

For sanctions and sovereign-risk analysis, the judgment reinforces that Russian administrative and judicial acts in Crimea were assessed against Convention standards and international humanitarian law, with direct implications for the legal reliability of titles and state acts in occupied territory. It also shows the Court separating claims against Ukraine from those tied to Russia’s control of Crimea, which matters when assessing jurisdiction, enforceability, and asset-chain risk.

Implications

Compliance and litigation teams should treat land, registry, and court actions in Crimea as legally contested and assess title provenance against the Convention/IHL framework referenced by the Court. The strike-out of the Ukraine complaints narrows forum and liability exposure on that side, while the Russia-related findings support challenges to property cancellations and other acts issued under the post-annexation legal order.