Şandru and Others v. Romania, No. 22465/03, ECtHR (Third Section), 8 December 2009

Use of force during political manifestations. Public order. Right to life. 

Art. 2 ECHR

1. During a 1989 demonstration against the Communist regime, President Ceauşescu ordered police and military personnel to resort to the use of force to repress dissent and re-establish public order. The repressive action resulted in several victims and other people seriously injured by gunshots. 

2. The ECtHR ruled that no effective investigation had been initiated into the massive use of lethal force, resulting in a violation of art. 2 ECHR. As a matter of fact, the investigation - still pending at the time of the application - had been assigned to military prosecutors who were subject to the principle of subordination to their hierarchy and therefore to the accused themselves.