THIRD SECTION
CASE OF VUKEV AND OTHERS v. BULGARIA
(Applications nos. 35275/21 and 2 others –
see appended list)
JUDGMENT
STRASBOURG
23 October 2025
This judgment is final but it may be subject to editorial revision.
In the case of Vukev and Others v. Bulgaria,
The European Court of Human Rights (Third Section), sitting as a Committee composed of:
Canòlic Mingorance Cairat, President,
Diana Kovatcheva,
Vasilka Sancin, judges,
and Viktoriya Maradudina, Acting Deputy Section Registrar,
Having deliberated in private on 2 October 2025,
Delivers the following judgment, which was adopted on that date:
PROCEDURE
1. The case originated in applications against Bulgaria lodged with the Court under Article 34 of the Convention for the Protection of Human Rights and Fundamental Freedoms (“the Convention”) on the various dates indicated in the appended table.
2. The applicants were represented by Mr V. Stoyanov, a lawyer practising in Pazardzhik.
3. The Bulgarian Government (“the Government”) were given notice of the applications.
THE FACTS
4. The list of applicants and the relevant details of the applications are set out in the appended table.
5. The applicants complained of the inadequate conditions of their detention.
THE LAW
JOINDER OF THE APPLICATIONS6. Having regard to the similar subject matter of the applications, the Court finds it appropriate to examine them jointly in a single judgment.
ALLEGED VIOLATION OF ARTICLE 3 OF THE CONVENTION7. The applicants complained of the inadequate conditions of their detention. They relied on Article 3 of the Convention.
8. The Court notes that the applicants were kept in detention in poor conditions. The details of the applicants’ detention are indicated in the appended table. The Court refers to the principles established in its case‑law regarding inadequate conditions of detention (see, for instance, Muršić v. Croatia [GC], no. 7334/13, §§ 96‑101, ECHR 2016). It reiterates in particular that a serious lack of space in a prison cell weighs heavily as a factor to be taken into account for the purpose of establishing whether the detention conditions described are “degrading” from the point of view of Article 3 and may disclose a violation, both alone or taken together with other shortcomings (see Muršić, cited above, §§ 122-41, and Ananyev and Others v. Russia, nos. 42525/07 and 60800/08, §§ 149‑59, 10 January 2012).
9. In the leading case of Neshkov and Others v. Bulgaria, nos. 36925/10 and 5 others, 27 January 2015, the Court already found a violation in respect of issues similar to those in the present case.
10. Having examined all the material submitted to it, the Court has not found any fact or argument capable of persuading it to reach a different conclusion on the admissibility and merits of these complaints. Having regard to its case-law on the subject, the Court considers that in the instant case the applicants’ conditions of detention were inadequate.
11. These complaints are therefore admissible and disclose a breach of Article 3 of the Convention.
APPLICATION OF ARTICLE 41 OF THE CONVENTION12. Regard being had to the documents in its possession and to its case‑law (see, in particular, Muršić, cited above, § 181), the Court considers it reasonable to award the sums indicated in the appended table.
FOR THESE REASONS, THE COURT, UNANIMOUSLY,
Decides to join the applications;Declares the applications admissible;Holds that these applications disclose a breach of Article 3 of the Convention concerning the inadequate conditions of detention;Holds(a) that the respondent State is to pay the applicants, within three months, the amounts indicated in the appended table, to be converted into the currency of the respondent State at the rate applicable at the date of settlement;
that from the expiry of the above-mentioned three months until settlement simple interest shall be payable on the above amounts at a rate equal to the marginal lending rate of the European Central Bank during the default period plus three percentage points.
Done in English, and notified in writing on 23 October 2025, pursuant to Rule 77 §§ 2 and 3 of the Rules of Court.
Viktoriya Maradudina Canòlic Mingorance Cairat
Acting Deputy Registrar President
APPENDIX
List of applications raising complaints under Article 3 of the Convention
(inadequate conditions of detention)
No.
Application no.
Date of introduction
Applicant’s name
Year of birth
Facility
Start and end date
Duration
Specific grievances
Domestic award
(in euros)
Amount awarded for non-pecuniary damage per applicant (in euros)[1]
Amount awarded for costs and expenses per application
(in euros)[2]
35275/21
05/07/2021
Aleksandar Dimitrov VUKEV
1985
Pazardzhik Prison
01/09/2014 to
31/10/2015
1 year(s) and 2 month(s)
overcrowding
522
(BGN 920 plus interest BGN 101)
5,100
250
35286/21
05/07/2021
Ivan Todorov TRANENSKI
1981
Ruse Pre-Trial Detention Centre
10/02/2015 to
07/04/2015
1 month(s) and 29 day(s)
Pazardzhik Prison
08/04/2015 to
07/04/2016
1 year(s)
lack of or insufficient natural light, lack of fresh air, lack of or insufficient physical exercise in fresh air, lack of privacy for toilet
overcrowding
494
(BGN 900 plus interest BGN 66)
5,100
250
38534/21
23/07/2021
Nikola Slavchev NIKOLOV
1983
Pazardzhik Pre-Trial Detention Centre
01/11/2016 to
25/11/2016
25 day(s)
Pazardzhik Prison
26/11/2016 to
31/12/2016
1 month(s) and 6 day(s)
Pazardzhik Prison
01/01/2017 to
30/04/2017
4 month(s)
lack of fresh air, no or restricted access to running water, lack of or insufficient physical exercise in fresh air, lack of or insufficient natural light
lack of fresh air, lack of or insufficient natural light, lack of or insufficient physical exercise in fresh air, overcrowding
lack of or insufficient physical exercise in fresh air, lack of or insufficient natural light, lack of fresh air, overcrowding
282
(BGN 500 plus interest BGN 51)
3,000
250
[1] Plus any tax that may be chargeable to the applicants.
[2] Plus any tax that may be chargeable to the applicants.