At its Human Rights meeting from 15 to 17 September, the Committee of Ministers ended its supervision of the execution of the European Court’s judgment in the case of Enache v. Romania.
The case concerned the applicant’s automatic classification as a “dangerous” prisoner in 1997 solely based on the severity of his sentence, resulting in a restrictive detention regime and poor material conditions, in violation of the prohibition of torture or inhuman or degrading treatment or punishment (Article 3 of the Convention). The Court also found a violation of Article 34 due to unjustified interference with the applicant’s right of individual petition.
In response to the judgment, the Romanian authorities have considerably improved the material conditions of detention and introduced important legislative and procedural reforms. Detainees are no longer automatically classified as dangerous and are now subject to an individualised assessment that can be challenged before judicial authorities. These developments align with the recommendations made by the European Committee for the Prevention of Torture (CPT) in the report on its 2022 visit.
As regards Article 34, the Committee noted that the prisoners’ right of individual petition with the Court is now fully guaranteed, and any interference is strictly limited and subject to legal safeguards.
The Committee welcomed these measures, which ensure compliance with the Court’s judgment, and concluded that all necessary individual and general measures have been taken.
Final resolution CM/ResDH(2025)260
