Resolution CM/ResDH(2025)272
Execution of the judgments of the European Court of Human Rights
Two cases against Bulgaria
(Adopted by the Committee of Ministers on 7 October 2025
at the 1539th meeting of the Ministers’ Deputies)
Application No.
Case
Judgment of
Final on
72059/16
PAVLOVI
01/02/2022
01/02/2022
23763/18
X AND Y
06/02/2020
06/02/2020
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 violation established on account of the authorities’ failure to take all measures which could reasonably be expected to enforce the applicants’ custody or contact rights (violation of Article 8);
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 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)680-rev);
Considering that the question of individual measures was resolved, given that in the Pavlovi case the child is already of age, and that in the X. and Y. case the enforcement proceedings were terminated in 2023 because the first applicant did not seek performance of enforcement steps in the course of two years and there is no data that she has sought enforcement thereafter;
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 Aneva and Others 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 required;
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;
DECIDES to continue to supervise the adoption of the necessary general measures in the Aneva and Others case;
DECIDES to close the examination of these cases.