Resolution CM/ResDH(2026)33
Execution of the judgment of the European Court of Human Rights
Sadio against Italy
(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
3571/17
SADIO
16/11/2023
16/11/2023
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 of Article 3 and 13 established on account of the inadequate material conditions of the applicant’s stay at the reception centre of Cona (Venise) between 2016 and 2017 and the lack of effective remedies to complain about them;
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(2026)6);
Considering that the question of individual measures was resolved, given that the applicant left the centre of Cona on 27 January 2017 and the just satisfaction awarded by the Court has been paid to him;
Taking note, in respect of the general measures, of the information provided on the closure of the centre of Cona and the progress achieved on the issue of the material conditions in first reception centres (CM/Del/Dec(2024)1501/H46-18 and CM/Del/Dec(2026)1553/H46-25);
Noting further that the question of the remaining measures required to prevent similar violations of Article 3 continues to be examined within the framework of the J.A. and Others v. Italy 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 these measures;
Recalling also that the question of the lack of effective remedies to bring before the national judicial authorities’ complaints related to the material conditions in reception centres (violation of Article 13) was examined in the case of Khlaifia and Others v. Italy (CM/ResDH(2021)424);
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 issue of the material conditions of stay in first reception centres in the group of cases J.A. and Others v. Italy; and
DECIDES to close the examination of this case.