Resolution CM/ResDH(2026)39
Execution of the judgments of the European Court of Human Rights
Six cases against Türkiye
(Adopted by the Committee of Ministers on 11 March 2026
at the 1553rd meeting of the Ministers’ Deputies)
Application No.
Case
Judgment of
Final on
40073/98
İhsan bİlgİn
27/07/2006
27/10/2006
23502/06
BENZER AND OTHERS
12/11/2013
24/03/2014
16281/10
AYDAN
12/03/2013
12/06/2013
62279/09
ATİMAN
23/09/2014
23/12/2014
44125/06
GÜLBAHAR ÖZER AND OTHERS
02/07/2013
02/10/2013
46820/09
KARATAŞ AND OTHERS
12/09/2017
12/12/2017
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 the unjustified use of force by members of the security forces during military and police operations, as well as the ineffectiveness of subsequent investigations;
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 plan and information 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 documents DH-DD(2022)778 and DH-DD(2026)153);
Noting that the in the Karataş and Others case, review carried out after the Court’s judgment revealed that the shortcomings in the investigation found by the Court have either been remedied or can no longer be remedied due to the passage of time and that therefore no further individual measures are possible; as regards the remaining cases, noting with deep regret that no further individual measures can be taken because of the applicable prescription periods;
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 Erdoğan and Others v. Turkey (19807/92) group of cases 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 the unjustified use of force by security forces during operations and ineffectiveness of subsequent investigations;
DECLARES that it has exercised its functions under Article 46, paragraph 2, of the Convention in these cases;
CONCLUDES that no further individual measures are possible in these cases;
DECIDES to continue to supervise the adoption of the necessary general measures concerning the unjustified use of force by security forces during operations and ineffectiveness of subsequent investigations in the Erdoğan and Others v. Turkey (19807/92) group of cases;
DECIDES to close the examination of these cases.