Attalidis and Others v. Greece — ECtHR finds Korydallos overcrowding violated Article 3

Case
Case of Attalidis and Others v. Greece
Court
European Court of Human Rights
Date Decided
24 September 2026
Citation
ECLI:CE:ECHR:2026:0924JUD005747917
Topics
prison overcrowding, detention conditions, Article 3, domestic remedies

Background

Nine applicants complained about conditions at Korydallos Prison in Greece, principally overcrowding and inadequate personal space. Some also alleged that remand and convicted prisoners had been held together, raised an Article 13 complaint concerning the lack of an effective remedy, and made further complaints about detention and medical care.

Three applicants were no longer pursued: two did not provide the requested updated information, while one had died and no heir sought to continue the case. Another applicant, Panayot Puci, had been transferred to Thiva Prison Rehabilitation Centre before applying to Strasbourg and sought redress only for past conditions at Korydallos.

The Court’s Holding

The Court struck out the applications of Astrit Bujaraj, Jhad Karam and Epaminondas Papadopoulos under Article 37 § 1(a). It rejected Puci’s Article 3 conditions complaint for non-exhaustion because, after his transfer, an action for damages under Article 105 of the Introductory Law to the Civil Code was an available domestic remedy for the alleged past violation.

For Dimitris Attalidis, Nikola Cela, Palaj Kleanth, Michail Narliotis and Charles Ngimba/Zistokele, the Court found an Article 3 violation. The evidence established that they had less than 3 square metres of personal space during relevant periods in Korydallos, against a background of persistent prison overcrowding. The Court awarded them non-pecuniary damages ranging from EUR 2,900 to EUR 11,400, plus EUR 1,000 jointly for costs and expenses.

Key Takeaways

  • Detention in Korydallos cells providing less than 3 square metres of personal space breached Article 3 for five applicants.
  • Where an applicant has already left the allegedly unsuitable prison and seeks compensation for past conditions, an available domestic damages remedy must generally be exhausted.
  • Having found the Article 3 violation based on overcrowding, the Court did not separately examine the Article 13 complaint or other Article 3 allegations about detention with convicted prisoners.

Why It Matters

The judgment applies the Court’s established overcrowding framework to Korydallos Prison and underscores that serious space shortages can themselves establish degrading detention conditions. It also distinguishes between remedies required to end an ongoing violation and remedies that must be used when an applicant seeks redress only for a completed period of detention.

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