Background
Dzintars Jezdauckis, a Latvian national residing in the United Kingdom since September 2021, was arrested on 30 January 2024 pursuant to a European arrest warrant issued by Latvia. He was accused of conspiracy to produce and sell large quantities of narcotic substances allegedly between May and July 2017. Notably, Jezdauckis was imprisoned in Latvia during the period when these offences are alleged to have occurred. He had previously served an eight-year sentence at Daugavgriva Prison in Latvia for drug supply convictions and was subject to police supervision before departing Latvia.
The District Judge ordered extradition on 28 June 2024. Jezdauckis appealed to the High Court on two grounds: (1) that extradition would breach his Article 3 ECHR rights (protection against torture and inhuman or degrading treatment) and (2) that it would breach his Article 8 ECHR rights (right to private and family life). He had lived in the UK with his partner and her children and had maintained family ties there.
The Court’s Holding
Justice Kimblin upheld the extradition order, but only after obtaining specific assurances from Latvia regarding prison placement and conditions. On the Article 3 claim, the Court initially identified a real risk of degrading treatment given the Appellant’s particular circumstances. The Appellant had provided expert medical evidence from Dr. Juliet Cohen documenting approximately 22 lesions consistent with assault during his prior imprisonment, as well as evidence of attempted sexual violence. He suffered from depression and anxiety with significant suicide risk. The Court of Human Rights and the European Committee for the Prevention of Torture (CPT) had documented persistent inter-prisoner violence in Latvian prisons arising from an informal prisoner hierarchy based on a “caste system” that categorises inmates at entry.
However, the Court found that general prison conditions in Latvia do not breach Article 3, relying on the reasoning in *Sostacks v Prosecutor General’s Office of Latvia* and the strong presumption that Council of Europe signatories comply with Convention obligations. Critically, the Court distinguished this case based on the Appellant’s specific history of documented abuse and his likely placement in a position of vulnerability within the prison hierarchy. The Court therefore ordered enquiries regarding: (1) which prison would hold him; (2) how that prison’s accommodation would mitigate inter-prisoner violence risks; and (3) post-conviction placement and protections. Upon receiving Latvia’s April 2026 response confirming the availability of single-occupancy cells at the new Liepāja Prison, allocation procedures, and enhanced supervision measures, the Court found these assurances sufficient to eliminate the real risk of degrading treatment. The Court emphasised that single-occupancy cells represented the “gold standard” for addressing inter-prisoner violence and that Latvia’s concrete investment in new facilities demonstrated genuine awareness and commitment to reform. The Court ordered that its judgment be transmitted to Latvian authorities to ensure findings would be respected.
On the Article 8 claim, the Court refused permission to appeal, finding that the serious nature of the allegations, the Appellant’s prior conviction for similar offences, and the weighty public interest in ensuring accused persons face trial decisively outweighed his family ties in the United Kingdom, consistent with *Andrysiewicz v Poland* [2025] UKSC 23.
Key Takeaways
- A prior history of documented abuse in a specific prison can establish a real risk of Article 3 breach for that individual even where general prison conditions meet Convention standards
- Courts will require specific, detailed assurances regarding placement and conditions when an individual’s circumstances suggest heightened vulnerability
- The availability of single-occupancy cell accommodation can sufficiently mitigate risks arising from informal prisoner hierarchies and inter-prisoner violence
- Article 8 protection in extradition cases remains narrow; family ties do not typically outweigh the public interest in prosecution of serious criminal allegations
- The principle of mutual trust between Council of Europe signatories creates a strong presumption in favour of extradition that can be overcome only by substantial grounds demonstrating real risk
Why It Matters
This decision clarifies the intersection of individual vulnerability and systemic prison conditions in Article 3 extradition analysis. While prior case law (*Sostacks*, *Vascenkovs*) had held that documented systemic problems in Latvian prisons did not breach Article 3 generally, *Jezdauckis* establishes that an individual with proven prior experience of abuse in the same prison system may present a different case. The decision recognises that torture and degrading treatment claims are not purely generalised but can be particular to the requesting person’s circumstances and history.
The judgment also illustrates the practical mechanisms by which courts ensure Article 3 compliance: rather than denying extradition outright, courts may impose conditions by requiring specific information and assurances from requesting states. This pragmatic approach maintains international comity whilst protecting fundamental rights. Significantly, the judgment signals that infrastructural improvements—here, new prisons with single-occupancy cells—can be sufficiently credible where accompanied by legal procedures for placement and evidence of reform. The decision thus creates a model for future cases in which applicants allege prior victimisation in a particular prison system: they must provide individualised evidence (medical documentation, eyewitness accounts, expert assessment) of their past abuse and their likely vulnerability if returned, and requesting states may respond with specific, detailed assurances rather than general assertions of compliance.