The European Court of Human Rights (ECHR) has ruled that citizens in Armenia lack an effective means of complaining about the excessive length of court proceedings and obtaining compensation.

The ECHR ruled against Armenia on May 21, 2026 in the joint case of Lena Hakobyan and Avetik Ghazaryan’s family, finding violations of the rights to a fair trial (Article 6 of the European Convention) and to an effective remedy (Article 13). The Armenian government was ordered to pay the applicants a total of €10,600 in compensation.

The cases concern the length of proceedings in civil and administrative courts and the availability of effective domestic remedies to claim compensation for the excessive length of proceedings.

In one of the cases, Avetik Ghazaryan and his family members, his wife and two children, filed a claim against the Government in 2015. They were allocated an apartment with a total area of ​​71 square meters by the 1991 decision of the Executive Committee of the Spandaryan Regional Council of People's Deputies of the Armenian SSR. However, they did not receive either the apartment or any monetary compensation equivalent to it. They demanded an apartment equivalent to the allocated apartment or compensation.

In court, the family members claimed that the Republic of Armenia had not in any way pursued the restoration of their violated right to provide the apartment or compensation equivalent to it.

The family members' claim was rejected, and the case cycle in three instances lasted more than seven years and eight months. The Court of Cassation (chairman and rapporteur: Ruzana Hakobyan, judges: Hovsep Bedevyan, Arman Tovmasyan, Kristine Mkoyan) made the final decision on the case on April 28, 2023.

The other case, in which the applicants were Lena Hakobyan and her family members, concerned a claim to return a plot of land from illegal possession and to demolish buildings built on that plot. The case had been pending in the courts for thirteen years and five months.

The applicants argued before the ECHR that Armenia’s domestic legal system did not provide for any accessible and effective remedy for complaints about the length of proceedings. They argued that the contested remedy did not satisfy the requirements of the Armenian civil courts, which were excessively long, which affected the effectiveness of any such remedy.

In particular, the problem of lengthy proceedings in Armenia was systemic. Concerns were also raised before the ECHR that in some cases the changes made to the system had been piecemeal and the application of disciplinary liability to judges had been selective, while the problem of lengthy proceedings remained unresolved.

The ECHR concluded that the length of the proceedings had clearly exceeded the “reasonable time” requirement. The Court also noted that the compensation mechanism provided for in Armenian law was not functioning effectively.

The ECHR called on the Armenian authorities to establish, as a matter of priority, a specific and effective compensation mechanism for the examination of complaints about excessively long proceedings, which would meet the standards established by the European Court.

The ECHR also stressed that such a measure should be applicable not only to future violations, but also to violations that have occurred in the past and have not yet been redressed, allowing for effective compensation to be provided both in cases that are still pending and in cases that have already been concluded.

The ECHR also considered the practice in Armenia. The European Court noted that in compensation cases, domestic courts had placed the burden of proof on the claimant to show that it could have been heard more quickly or that the hearings could reasonably have been scheduled earlier. In one such example (YD/31299/02/19), the main proceedings in the Administrative Court lasted five and a half years. It took the court another year to send the plaintiff the judicial act.

In another example (YD/1152/02/20), the court required the plaintiff to prove that the relevant hearings could reasonably have been scheduled earlier. It is also unclear how the plaintiff could have expedited the proceedings, as suggested by the Court of Appeal, when such a possibility did not exist under domestic law, etc.

The ECHR noted that the procedure for examining compensation claims provided for in Articles 162.1 and 1087.2 of the Civil Code of the Republic of Armenia is not sufficiently effective to compensate for the damage caused by the excessive length of the proceedings. There are no specific time limits set by law for the examination of such claims, and they are examined in the ordinary civil procedure.

The court has also emphasized that the time limits for the examination of cases concerning compensation cannot be assessed in the same way as the question of the reasonable time for the main proceedings. The reason is that such compensation cases are usually not complex and should be examined in a more expeditious manner.

The ECHR has noted that, although the compensation procedure has been in place since January 2016, i.e. for more than a decade, and the Armenian government has only provided six examples of the conclusion of court cases in favor of the application of this procedure, which seems to confirm that it is not considered effective.

It was also noted that the length of the proceedings, which ranges from 7 to 13 years, is excessive and does not comply with the reasonable time requirement set out in Article 6 § 1 of the European Convention. Consequently, this right was violated for all applicants. The ECHR also found a violation of Article 13 of the Convention (effective remedy) because the applicants did not have an effective remedy at the domestic level for their complaint about the excessive length of the proceedings.

Citizen died without seeing the resolution of the dispute

The examination of cases in Armenian courts with violations of the reasonable time requirement continues. In this regard, civil and administrative courts are particularly prominent. Sometimes the plaintiffs die and never see how their disputes were resolved.

In October 2014, citizen E.H. filed a lawsuit with the General Jurisdiction Court of Arabkir and Kanaker-Zeytun Administrative Districts of Yerevan, demanding to declare the notarized contract of donation of a residential house and land plot invalid and to apply the consequences of invalidity (YAKD/4351/02/14).

By its decision of October 22, 2014, the court refused to accept the lawsuit for proceedings. The citizen appealed that decision, and the Civil Court of Appeal overturned the court’s decision on December 15, 2014.

The case was accepted for proceedings on February 5, 2015.

During the court session, the representative reported that the plaintiff had died. On that basis, the court On April 17, 2020, the court suspended the proceedings of the case until the issue of his legal succession was resolved.

On July 22, 2025, the court applied to the Notary Chamber to obtain the necessary evidence. On October 30, 2025, a certificate of inheritance was submitted to the court, according to which the deceased citizen's son was recognized as the heir to the property. The court resumed the examination of the case.

The next court hearing in this case is scheduled for September 2026. It will soon be twelve years since this case has been examined in court.

In another case, a citizen filed a lawsuit against the Yerevan Municipality in February 2020 with a demand to oblige it to legalize the land plot (VD/1221/05/20). The examination of the administrative case is still ongoing. The court of first instance granted the claim in 2021. The Yerevan Municipality filed an appeal against the decision. The Administrative Court of Appeal overturned the verdict in October 2023 and sent it for a new trial.

In February 2024, the case, which was accepted for a new trial, was accepted for proceedings, and on December 25, 2025, the citizen's claim was rejected. This time, the citizen filed an appeal. The complaint was accepted for proceedings on April 8, and the first hearing on the case was scheduled for about two years and 3 months after the acceptance of proceedings.

Considering that the claim was filed in 2020 and a hearing is still scheduled for 2028, it turns out that the case can only be resolved after eight years. However, this is not the end. One of the parties can appeal the Court of Appeal’s verdict to the Court of Cassation or the court can overturn the case and send it for a new trial again, starting a new cycle.

In another case, a citizen filed a lawsuit with the court demanding the cancellation of the decision of the Urban Development, Technical and Fire Safety Inspection Body of April 28, 2026 (VD/10802/05/26). On June 30, 2026, the Administrative Court accepted the lawsuit for proceedings and set the date of publication of the judicial act in the case as September 13, 2028, that is, after two years and 2.5 months.

The same is true in the Administrative Appeals Court. For example, in September 2025, a citizen filed a lawsuit with the Administrative Court against the Yerevan Municipality demanding the invalidation of the decision “On Imposing an Administrative Fine” (VD/15102/05/25). The court rejected the lawsuit in May 2026, after which the citizen filed an appeal.

The Administrative Court of Appeal accepted the appeal on May 26, 2026 and set the date for the publication of the decision as May 12, 2028.

The judges of the Administrative Court note that they are overloaded compared to other courts, which is why they do not have time to quickly examine cases and make decisions.