Seeking Justice: Two Decades of Fighting Impunity for Enforced Disappearances in the North Caucasus by Elba Bendo

This is the sixth blog in a series featuring legal representatives and experts in the field of strategic litigation against torture, discussing the strategic impact of cases catalogued in Casebook 1.
In this blog post, Elba Bendo, Lawyer at the European Human Rights Advocacy Centre (EHRAC), examines the most strategic features in the Khashiyev and Akayeva v Russia case.
Two decades after the European Court of Human Rights rendered its judgment in Khashiyev and Akayeva v Russia, EHRAC and partners continue to actively seek justice, truth, and reparation for the victims of Russia’s atrocities in the North Caucasus.
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Elba Bendo

As one of the first judgments by the European Court of Human Rights on the Russian-Chechen wars, the Khashiyev group of cases marked the early stages of the efforts by victims and civil society to have the atrocities committed by Russian state forces against  North Caucasus communities documented before an international judicial mechanism.

The Court’s judgment in Khashiyev also set a precedent for how it would handle the hundreds of other cases that would later come before it concerning 150 civilians killed and 668 victims disappeared by Russian state forces in the region. The proliferation of these cases before the Court created a record of the systemic nature of the violations by Russian authorities and the climate of complete impunity surrounding these violations.

Two decades after the European Court of Human Rights rendered its judgment in Khashiyev and Akayeva v Russia, EHRAC and partners continue to actively seek justice, truth, and reparation for the victims of Russia’s atrocities in the North Caucasus.

Our strategy of continuing, over many years, to seek implementation of the judgments has focused on keeping these cases on the international agenda as the continuing violations they are, by outlining the continued suffering of relatives of victims who, to this day, do not know the fate of their loved ones – this suffering has increasingly been accepted by the Court as amounting to a violation of relatives’ right to be free from torture and inhuman treatment, in contravention of Article 3 of the European Convention on Human Rights.

We have also sought intervention in cases before the Court pertaining to similar human rights violations perpetrated by Russian-backed Chechen authorities in Chechnya and Russian forces in Ukraine, arguing that the Court must consider how the climate of impunity created by the practice of ineffective investigations into serious violations perpetrated during the war periods enables the perpetuation of similar violations today in the North Caucasus and Ukraine.

Five years ago, a Chechen lawyer and activist, Mariat Imaeva, brought to us the idea for an animation that seeks to capture the unspeakable suffering and immense strength of family members of disappeared victims. In a slight departure from our usual tools of advocacy, In Limbo, was co-produced in 2024 with the award-winning animation production studio NOMINT.

In January 2025, In Limbo was shown at the opening session of the first World Congress on Enforced Disappearances, bringing the suffering and the ongoing plight of relatives of disappeared victims from the North Caucasus to a global audience of relatives and advocates. It shows, first and foremost, that the search for what happened to the victims of enforced disappearances by Russian state authorities will not end until their fate is determined.

Casebook Series
The REDRESS Casebook series showcases around 80 case studies of strategic litigation against torture from around the world to illustrate best practices and help strengthen the capacity of human rights lawyers worldwide. It was produced with the financial assistance from the EU under the United Against Torture Consortium Initiative.
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