Resolution CM/ResDH(2026)113
Execution of the judgment of the European Court of Human Rights
P.H. against Slovakia
(Adopted by the Committee of Ministers on 11 June 2026
at the 1563rd meeting of the Ministers’ Deputies)
Application No.
Case
Judgment of
Final on
37574/19
P.H.
08/09/2022
08/12/2022
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 violations established on account of the failure to protect the physical well-being of an unaccompanied Roma minor in police custody, as well as the ineffective investigation;
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 measures adopted in order to execute the judgment including the information provided regarding the payment of the just satisfaction awarded by the Court (see document DH-DD(2026)392);
Noting with deep regret that no further individual measures could be taken in this case, given that the statute of limitations for the offences concerned had expired;
Considering that the question of the general measures required by Article 46, paragraph 1, with regard to the protection of physical well-being in police custody (substantive violation of Article 2) had been resolved, notably through a wide range of awareness-raising measures;
Recalling that the question of general measures required in response to the shortcomings found by the Court in this judgment concerning ineffective investigation continues to be examined within the framework of the R.R. and R.D. group of cases (No. 20649/18), 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 in relation to ineffective investigations;
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 ineffective investigations in the R.R. and R.D. group of cases; and
DECIDES to close the examination of this case.