ECtHR judgments against Greece in 2025 for violations of Article 3 ECHR

In 2025, the ECtHR issued seven judgments finding Greece in violation of Article 3 ECHR (prohibition of torture, inhuman or degrading treatment). These cases concerned: the reception and living conditions of asylum seekers, detention conditions in police stations and prisons, incidents of police violence and one case involving pushbacks, where the Court referred to this practice as systematic by Greek authorities.

In any event, it should be noted that this is a landmark ECtHR judgment, as also highlighted in the 7‑1‑2025 article of the Greek Council for Refugees.

2. Panayiotopoulos and Others v. Greece (no. 44758/20), judgment of 21 January 2025

Three Greek nationals of Roma origin complained of:

• police violence during arrest, transfer, and detention,
• ineffective investigation,
• and racially motivated treatment.

The Court found violations of:

• Article 3 (procedural),
• Article 3 (substantive) for the first and third applicants,
• Article 14 + Article 3 (procedural) for failure to investigate possible racial motives.

3. Fragkopoulos and Others v. Greece (no. 550/17), judgment of 23 January 2025

This case concerned the detention conditions of six applicants in Diavata Prison.The Court, referring to its prior case‑law on Diavata, found that the conditions amounted to inhuman and degrading treatment, violating Article 3.

4. Poulopoulos v. Greece (no. 27936/18), judgment of 20 March 2025

The case concerns the applicant’s detention conditions in the Korydallos Prison Hospital. The applicant, who suffers from an incurable illness, complained about the poor conditions of his detention as well as the lack of an effective remedy that would allow him to challenge those conditions. 

The ECtHR, after referring, among other things, to its earlier judgments concerning detention conditions in the Korydallos Prison Hospital, in which it had already found violations of Article 3, and placing particular emphasis on the applicant’s extremely vulnerable situation as a detainee suffering from an incurable illness, concluded that the conditions under which he was held were incompatible with Article 3 ECHR and therefore constituted a violation of that provision. Furthermore, the Court found a violation of Article 13 ECHR, noting, among other things, that the effectiveness of the available remedy (a request for release) had been undermined by the excessive length of the relevant proceedings. 

5. M.Y. and Others v. Greece (nos. 51980/19, 55988/19, 56843/19, 61303/19, 15463/20, 19803/20), judgment of 19 June 2025

The case concerns the reception and detention conditions of the thirty‑six applicants, all of whom were unaccompanied minors at the time they lodged their applications before the Court. The ECtHR, referring among other things to shortcomings, delays, and deficiencies in their reception conditions, as well as to the conditions of their detention in the context of protective custody and/or in pre‑removal detention centres, and to the living conditions in the Malakasa RIC, and relying on its established case‑law on similar issues, concluded that the treatment to which the applicants were subjected constituted a violation of Article 3 ECHR (see §§14–19 of the judgment). Furthermore, the Court, finding no reason to depart from its settled case‑law on the matter, held that in this case there had also been a violation of Article 5 §§1 and 4 ECHR. 

6. A.I. and Others v. Greece (nos. 11588/20, 13865/20, 17152/20), judgment of 19 June 2025

The case concerns the living conditions of the three applicants, all of whom were unaccompanied minors at the time they lodged their applications before the Court, as well as the placement of one of them in protective custody.

The ECtHR noted, among other things, that the applicants had been forced to look after themselves for extended periods in a foreign country, under conditions unsuitable for their age and incompatible with human dignity. It concluded that the treatment to which they were subjected, as homeless unaccompanied minors, amounted to a violation of Article 3 ECHR.

Furthermore, examining the complaint of one applicant (application no. 11588/20) regarding his placement in protective custody, the Court held – referring to its established case‑law on the matter—that there had also been a violation of Article 5 §1 ECHR.

7. B.F. v. Greece (no. 59816/13), judgment of 14 October 2025

The case concerns, primarily, the conditions of detention in police facilities. The applicant, an Iranian national seeking asylum, complained, among other things, about the conditions of his detention at the Kolonos Police Station, as well as the fact that he did not have access to an effective remedy that would allow him to challenge those conditions.

The ECtHR, noting among other things that the applicant had been detained for 2 months and 18 days at the Kolonos Police Station – a facility which, by its very nature, is not designed for prolonged periods of detention – found that there had been a violation of Article 3 ECHR (see §§47–52).

Furthermore, the Court concluded that there had been a violation of Article 13 in conjunction with Article 3, noting, among other things, that the applicant’s claims regarding the impact of detention on his health, the adequacy of medical care, and the detention conditions were either not examined or were examined summarily and without sufficient reasoning by the domestic courts (see §§55–61).

Finally, the Court held that there had not been a violation of Article 5 §1 of the Convention in this case (see §§69–77), and considered that there was no need to examine the complaint separately under Article 5 §4, as the main legal issue had already been addressed under Article 13.