Background
Mehmet Ali Demirci applied to the European Court of Human Rights on 4 September 2020, complaining under Article 3 of the Convention about inadequate conditions during his detention in Konya E-Type Closed Prison.
Between September 2017 and May 2018, he was held in three wards where the personal space recorded per inmate was 2.31, 1.69 and 2.17 square metres respectively. The appendix identified overcrowding in each ward; the wards held between 32 and 36 inmates and each had one toilet. The Turkish Constitutional Court had decided his complaint on 8 June 2020.
The Court’s Holding
The Court unanimously declared the application admissible and held that the inadequate detention conditions breached Article 3. It applied its established principles on prison overcrowding, under which a serious lack of personal space weighs heavily in assessing whether detention is degrading.
The Court noted that it had already found violations concerning similar issues in İlerde and Others v. Türkiye. Having examined the material before it, it found no basis to depart from that conclusion and held that Demirci’s detention conditions were inadequate.
Key Takeaways
- Detention in overcrowded prison wards with very limited personal space breached Article 3.
- The Court followed its prior case-law, including its earlier leading judgment concerning similar conditions in Türkiye.
- Türkiye must pay Demirci EUR 1,000 for non-pecuniary damage and EUR 250 for costs and expenses within three months, plus any applicable tax and default interest.
Why It Matters
The judgment reiterates that severe overcrowding can itself, or together with other shortcomings, make detention conditions incompatible with Article 3. It also confirms the Court’s continued application of its established approach to similar overcrowding complaints from Türkiye.