Case Brief: ECtHR (Application 9049/06): Use of Force against Demonstrators – Özalp Ulusoy v Turkey
The ECtHR found that Turkey had violated Article 3 ECHR with respect to:
– content: for the excessive and unjustified use of force against the protesters (para 45).
– procedure: for failure to investigate the applicant’s claim and ensure that police officers can be individually identified (in case of potential prosecution) (paras 53-54).
The ECtHR also found Turkey to have violated Article 11 ECHR as the use of force against the demonstrators was disproportionate and unnecessary to keep public order (para 78).