ECtHR judgments against Greece in 2025 for violations of Article 2 ECHR

In 2025, the European Court of Human Rights (ECtHR) issued two judgments finding that Greece violated Article 2 of the European Convention on Human Rights (right to life), both in its substantive and procedural dimensions. The first case concerned the death of a minor during a boat‑interception operation near Symi in August 2015.The second concerned the shipwreck of a vessel off Agathonisi in March 2018.

ECtHR findings

Procedural violation of Article 2:  

The Court found significant gaps and omissions in the national investigation, leading to loss of evidence and undermining its effectiveness (paras. 93–104).

Substantive violation of Article 2:  

The Court held that the coast guard officers should have considered the likelihood of additional passengers, that firing at an overcrowded and panicked vessel was extremely dangerous, and that the operation was not conducted in a way that minimised lethal force or protected life (paras. 131–155).

2. F.M. and Others v. Greece (no. 17622/21), judgment of 14 October 2025

This case concerns a shipwreck in March 2018 off Agathonisi. The applicants — three of whom survived the incident — alleged that:

• the authorities’ acts and omissions put their lives at risk,
• their relatives died during the shipwreck, and
• the subsequent investigations were inadequate.

ECtHR findings

Procedural violation of Article 2:  

The Court noted serious doubts about the independence of the investigations and highlighted major deficiencies in the forensic reports, which made it impossible to determine the date of the shipwreck (paras. 222–227).

Substantive violation of Article 2:  

The Court found that the Greek authorities, who knew or should have known of the real and immediate risk to the lives of those on board, failed to take reasonable measures to provide the level of protection required under Article 2 (paras. 286–309).