Resolution CM/ResDH(2026)85
Execution of the judgments of the European Court of Human Rights
Four cases against Poland
(Adopted by the Committee of Ministers on 29 April 2026
at the 1558th meeting of the Ministers’ Deputies)
Application No.
Case
Judgment of
Final on
76505/14
BEDNARZ
13/06/2019
13/06/2019
65970/12
DZIUNIKOWSKI
26/09/2019
26/09/2019
24913/15
JABŁOŃSKA
14/05/2020
14/08/2020
37023/13
KANCIAŁ
23/05/2019
23/08/2019
The Committee of Ministers, under the terms of Article 46, paragraph 2, of the Convention for the Protection of Human Rights and Fundamental Freedoms, which provides that the Committee supervises the execution of final judgments of the European Court of Human Rights (hereinafter “the Convention” and “the Court”),
Having regard to the final judgments transmitted by the Court to the Committee in these cases and to the violations established on account of excessive use of force by the Police officers in the case of Kanciał and ineffectiveness of investigations in this respect in the cases of Bednarz, Dziunikowski, Jabłońska and Kanciał;
Recalling the respondent State’s obligation, under Article 46, paragraph 1, of the Convention, to abide by all final judgments in cases to which it has been a party and that this obligation entails, over and above the payment of any sums awarded by the Court, the adoption by the authorities of the respondent State, where required:
- of individual measures to put an end to violations established and erase their consequences so as to achieve as far as possible restitutio in integrum; and
- of general measures preventing similar violations;
Having invited the government of the respondent State to inform the Committee of the measures taken to comply with the above-mentioned obligation;
Having examined the action report provided by the government indicating the individual measures adopted to execute the judgments including the information provided regarding the payment of the just satisfaction awarded by the Court (see document DH-DD(2025)1441);
Considering that the question of individual measures was resolved, given that decisions on discontinuation of investigations were re-examined by the Prosecution following the Court’s judgments;
Recalling that the question of general measures required in response to the shortcomings found by the Court in these judgments continues to be examined within the framework of the Kuchta and Mętel group also in the light of the Court’s findings in these cases, and that the closure of these cases therefore in no way prejudges the Committee’s evaluation of the general measures in relation to excessive use of force by the Police officers and ineffectiveness of investigations in this respect;
DECLARES that it has exercised its functions under Article 46, paragraph 2, of the Convention in these cases;
CONCLUDES that the necessary individual measures have been adopted;
DECIDES to continue to supervise the adoption of the necessary general measures concerning excessive use of force by the Police officers and ineffectiveness of investigations in this respect in the Kuchta and Mętel group of cases;
DECIDES to close the examination of these cases.