Resolution CM/ResDH(2026)60
Execution of the judgment of the European Court of Human Rights
Bumbeș against Romania
(Adopted by the Committee of Ministers on 8 April 2026
at the 1556th meeting of the Ministers’ Deputies)
Application No.
Case
Judgment of
Final on
18079/15
BUMBEȘ
03/05/2022
03/08/2022
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 judgment transmitted by the Court to the Committee in this case and to the violation of Article 10 of the Convention established on account of the unjustified interference with the freedom of expression due to the imposition of a fine for the applicant’s involvement in a short and peaceful gathering;
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 judgment including the information provided regarding the payment of the just satisfaction awarded by the Court (see document DH-DD(2025)1126);
Considering that the question of individual measures was resolved, given that the fine imposed on the applicant was fully covered by the total amount awarded by the Court, including non-pecuniary damage, no further individual measures are required;
Recalling that the question of general measures required in response to the shortcomings found by the Court in this judgment continues to be examined within the framework of the Chitic v. Romania (Application No. 6512/13) group of cases also in the light of the Court’s findings in this case, and that the closure of this case therefore in no way prejudges the Committee’s evaluation of the general measures concerning the unjustified interference with the freedom of expression due to the imposition of fines during political demonstrations;
DECLARES that it has exercised its functions under Article 46, paragraph 2, of the Convention in this case;
CONCLUDES that the question of individual measures has been resolved;
DECIDES to continue to supervise the adoption of the necessary general measures concerning the unjustified interference with the freedom of expression due to the imposition of fines during political demonstrations in the case of Chitic v. Romania group of cases (Application No. 6512/13);
DECIDES to close the examination of this case.