Tagayeva and Others v. Russia, No. 26562/07 and other 6, ECtHR (First Section); 18 September 2017

Art. 13 ECHR is important to establish the truth. Parliamentary commissions cannot replace the investigative obligations arising from Art. 2 and 3 ECHR. 

Art. 2 ECHR
Art. 13 ECHR

1. It is particularly important within the meaning of the Art. 13 ECHR to access information and to establish the truth for victims of alleged violations of conventional rights, in order to guarantee justice and prevent the immunity of perpetrators. In the instant case, there has been no breach of Art. 13 ECHR.

2. Though fundamental, inter alia, to draw lessons from the past, raise awareness of the current rules and dissuade from future violations, the final reports delivered by parliamentary commission, appointed to establish “historical truths”, cannot be regarded as satisfying the procedural obligations arising from Art. 2 and 3 ECHR. In this case, there has been a breach of Art.  2 ECHR.
(Case relating to the siege of the school in Beslan school, occurred in 2004, by Chechen separatist terrorists, and to the following rescue-operation by the Russian authorities).