CEDH · CASELAW;JUDGMENTS;CHAMBER;ENG — 21 mai 2026

.s800EAC49 { font-size:12pt } .sFE10DC93 { margin-top:0pt; margin-bottom:0pt; text-align:center } .sBB9EE52A { font-family:Arial } .s5E1364CA { margin-top:0pt; margin-bottom:12pt; text-align:center; page-break-inside:avoid; page-break-after:avoid; font-size:14pt } .sF2E0A612 { margin-top:48pt; margin-bottom:14pt; text-align:center; page-break-inside:avoid; page-break-after:avoid } .s29100277 { font-family:Arial; font-weight:bold } .s34DFC730 { margin-top:0pt; margin-bottom:0pt; text-align:center; page-break-inside:avoid; page-break-after:avoid } .sA36B60A1 { font-family:Arial; font-style:italic } .s339D85E6 { margin-top:0pt; margin-bottom:14pt; text-align:center; page-break-inside:avoid; page-break-after:avoid } .s780F5245 { border:0.75pt solid #000000; clear:both } .sE77B86B8 { margin-top:0pt; margin-bottom:0pt; text-align:justify; padding-top:1pt; padding-right:4pt; padding-left:4pt } .sEC28DD31 { margin-top:0pt; margin-bottom:0pt; text-align:justify; padding-right:4pt; padding-left:4pt } .s54452357 { margin-top:0pt; margin-bottom:0pt; text-indent:14.2pt; text-align:justify; padding-right:4pt; padding-left:4pt; font-size:10pt } .s55E5497F { margin-top:0pt; margin-bottom:0pt; text-indent:14.2pt; text-align:center; padding-right:4pt; padding-left:4pt; padding-bottom:1pt; font-size:10pt } .s6477A72F { margin-top:0pt; margin-bottom:6pt; text-indent:14.2pt; text-align:justify } .s10950C61 { margin-top:0pt; margin-bottom:0pt; text-indent:14.2pt; text-align:justify } .s2E932ED2 { margin-top:0pt; margin-bottom:0pt; font-size:11pt } .s32563E28 { margin-top:0pt; margin-bottom:0pt } .s4ACA9207 { page-break-before:always; clear:both; mso-break-type:section-break } .sA43C3626 { width:28.35pt; font-family:Arial; display:inline-block } .s3AAE10DF { margin-top:14pt; margin-bottom:12pt; text-align:justify; page-break-inside:avoid; page-break-after:avoid; font-size:14pt } .s3CA22BA { font-family:Arial; text-transform:uppercase } .s6B505E72 { margin:0pt; padding-left:0pt } .s329183A { margin-top:14pt; margin-bottom:12pt; text-align:justify; page-break-inside:avoid; page-break-after:avoid; font-family:Arial; font-size:14pt; text-transform:uppercase } .s743F3A55 { margin-right:0pt; margin-left:0pt; padding-left:0pt } .s6F9C7ED9 { margin-left:18.45pt; margin-bottom:12pt; text-indent:-18.45pt; page-break-inside:avoid; page-break-after:avoid; font-size:12pt } .s3936C9DD { width:11.78pt; font:7pt 'Times New Roman'; display:inline-block } .s119C1441 { margin-left:7.05pt; margin-bottom:12pt; text-indent:-17pt; page-break-inside:avoid; page-break-after:avoid; font-weight:bold; text-transform:none } .s5BDECA8 { width:5pt; font:7pt 'Times New Roman'; display:inline-block } .s3A692EA6 { margin-top:14pt; margin-bottom:6pt; text-align:center; page-break-after:avoid; font-size:10pt } .s9D48DD53 { margin-top:6pt; margin-left:21.25pt; margin-bottom:6pt; text-indent:7.1pt; text-align:justify; font-size:10pt } .s7ED160F0 { text-decoration:none } .sB343B0AA { font-family:Arial; font-size:6.67pt; vertical-align:super; color:#000000 } .s7D18490B { margin-top:14pt; margin-left:25.5pt; margin-bottom:12pt; text-indent:-17pt; text-align:justify; page-break-inside:avoid; page-break-after:avoid; font-family:Arial; font-weight:bold } .s66E9FC38 { font-family:Arial; font-size:8pt; vertical-align:super; color:#000000 } .sE5EEB06B { margin-top:14pt; margin-left:18.45pt; margin-bottom:12pt; text-indent:-18.45pt; text-align:justify; page-break-inside:avoid; page-break-after:avoid; font-family:Arial; text-transform:uppercase } .sBB64854C { width:8.45pt; font:7pt 'Times New Roman'; display:inline-block } .s99272BBB { margin-left:8.5pt; margin-bottom:6pt; page-break-inside:avoid; page-break-after:avoid; font-weight:normal; font-style:italic } .s54B12A03 { width:6.99pt; font:7pt 'Times New Roman'; display:inline-block } .s452883D { margin-top:14pt; margin-left:34pt; margin-bottom:6pt; text-indent:-17pt; text-align:justify; page-break-inside:avoid; page-break-after:avoid; font-family:Arial; font-style:italic } .s20FC8552 { font-family:Arial; font-size:11.5pt } .sDD998142 { margin-top:14pt; margin-left:17pt; margin-bottom:12pt; text-indent:-17pt; text-align:justify; page-break-inside:avoid; page-break-after:avoid; font-size:14pt } .sDECD9755 { margin-left:11.67pt; margin-bottom:12pt; text-align:justify; page-break-inside:avoid; page-break-after:avoid; padding-left:6.78pt; font-family:Arial; text-transform:uppercase } .sFBC99493 { font-style:italic } .s9804041A { margin-top:14pt; margin-left:19.85pt; margin-bottom:12pt; text-indent:-19.85pt; text-align:justify; page-break-inside:avoid; page-break-after:avoid; font-family:Arial; text-transform:uppercase } .s7B868B6A { width:9.85pt; font:7pt 'Times New Roman'; display:inline-block } .sAE715370 { margin-top:0pt; margin-bottom:0pt; text-indent:18.45pt; text-align:justify } .s2FA28896 { margin-left:8.55pt; margin-bottom:6pt; text-indent:-17.05pt; page-break-inside:avoid; page-break-after:avoid; font-size:10pt; font-weight:bold; font-style:normal } .sDBC81028 { width:4.83pt; font:7pt 'Times New Roman'; display:inline-block } .sD8E89A4 { margin-top:14pt; margin-left:42.55pt; margin-bottom:6pt; text-indent:-17.05pt; text-align:justify; page-break-inside:avoid; page-break-after:avoid; font-family:Arial; font-size:10pt; font-weight:bold } .s7AE800C3 { width:4.28pt; font:7pt 'Times New Roman'; display:inline-block } .s9CB9BE2 { margin-top:14pt; margin-left:51.05pt; margin-bottom:6pt; text-indent:-17.05pt; text-align:justify; page-break-inside:avoid; page-break-after:avoid; line-height:113%; font-family:Arial; font-size:10pt; font-style:italic } .s3970C00F { width:8.17pt; font:7pt 'Times New Roman'; display:inline-block } .s320E5A8E { width:5.95pt; font:7pt 'Times New Roman'; display:inline-block } .sDF837F39 { margin-top:14pt; margin-left:51.05pt; margin-bottom:6pt; text-indent:-17.05pt; text-align:justify; page-break-inside:avoid; page-break-after:avoid; font-family:Arial; font-size:10pt; font-style:italic } .sD051EF8 { width:3.72pt; font:7pt 'Times New Roman'; display:inline-block } .s4196892D { width:3.17pt; font:7pt 'Times New Roman'; display:inline-block } .sBD165FDE { width:5.39pt; font:7pt 'Times New Roman'; display:inline-block } .sE485344B { margin-top:14pt; margin-left:28.6pt; margin-bottom:12pt; text-align:justify; page-break-inside:avoid; page-break-after:avoid; padding-left:0.6pt; font-family:Arial; font-weight:bold } .sE8F2C496 { width:5.11pt; font:7pt 'Times New Roman'; display:inline-block } .sAAD7ECD0 { width:5.18pt; font:7pt 'Times New Roman'; display:inline-block } .s90EB8675 { margin-top:14pt; margin-left:53pt; margin-bottom:12pt; text-align:justify; page-break-inside:avoid; page-break-after:avoid; padding-left:8.2pt; font-family:Arial; font-weight:bold } .sD62BB3FA { width:7.11pt; font:7pt 'Times New Roman'; display:inline-block } .s9793A85B { margin-top:0pt; margin-bottom:0pt; text-indent:14.2pt } .s448F0C15 { margin-top:14pt; margin-left:18pt; margin-bottom:12pt; text-indent:-18pt; text-align:justify; page-break-inside:avoid; page-break-after:avoid; font-size:14pt } .sF0C78780 { margin-top:14pt; margin-left:17pt; margin-bottom:3pt; text-indent:-17pt; text-align:justify; font-family:Arial } .s5165BC52 { margin-left:17pt } .sE5BF05B1 { width:2.33pt; font:7pt 'Times New Roman'; display:inline-block } .sDB9EB187 { font-weight:bold } .s31FAC864 { margin-left:17.05pt; text-indent:-17.05pt; list-style-position:inside } .sE5C1F6E3 { width:3.33pt; font:7pt 'Times New Roman'; display:inline-block } .s1EDC9B7E { margin-top:0pt; margin-left:51.05pt; margin-bottom:0pt; text-align:justify } .sD27F934 { margin-left:51.05pt; text-indent:-17.05pt; text-align:justify; font-family:Arial } .s4B65A808 { margin-left:34pt; text-indent:-17pt; text-align:justify; font-family:Arial } .s2D9C6089 { margin-top:12pt; margin-bottom:12pt; text-indent:14.2pt; text-align:justify; page-break-inside:avoid; page-break-after:avoid } .s69DCC830 { margin-top:36pt; margin-bottom:0pt } .sC986E16F { font-family:Arial; color:#ffffff } .sB4BC8881 { width:33.89pt; font-family:Arial; display:inline-block } .s5CE24FBA { width:136.43pt; font-family:Arial; display:inline-block } .sF993D337 { width:25.88pt; font-family:Arial; display:inline-block } .sF78227B2 { width:156.43pt; font-family:Arial; display:inline-block } .s75A32C27 { border-collapse:collapse } .sE89C19BF { border-style:solid; border-width:0.75pt; padding:1.4pt 5.03pt; vertical-align:top; background-color:#dfdfdf } .s2EF62ED2 { margin-top:0pt; margin-bottom:0pt; font-size:12pt } .sE1A7A04C { font-family:Arial; font-weight:bold; color:#424242 } .s598389F9 { margin-top:0pt; margin-bottom:0pt; text-align:center; font-size:12pt } .sD8909BE6 { border:0.75pt solid #838383; padding:1.4pt 5.03pt; vertical-align:top } .s598389F7 { margin-top:0pt; margin-bottom:0pt; text-align:center; font-size:10pt } .sADADF4A7 { font-family:Arial; text-decoration:underline } .sF6A12959 { width:33%; height:1px; text-align:left } .s85226119 { margin-top:0pt; margin-bottom:0pt; text-align:justify; font-size:10pt } .s653E6C45 { font-family:Arial; font-size:6.67pt; vertical-align:super; color:#0069d6 } .fixListIndent { list-style-position: inside }   FIFTH SECTION CASE OF LENA HAKOBYAN AND OTHERS v. ARMENIA (Applications nos. 13721/23 and 34245/23)     JUDGMENT   Art 6 § 1 • Reasonable time • Excessive length of civil and administrative proceedings ranging from seven to thirteen   years Art 13 (+ Art 6 § 1) • No effective remedy Art 46 • Execution of judgment • General measures • Respondent State to put in place, as a matter of priority, a compensatory remedy specifically dedicated to complaints of excessive length of proceedings in line with the Court’s criteria, without ruling out the possibility of also introducing an acceleratory remedy   Prepared by the Registry. Does not bind the Court.   STRASBOURG 21 May 2026     This judgment will become final in the circumstances set out in Article 44 § 2 of the Convention. It may be subject to editorial revision.   In the case of Lena Hakobyan and Others v. Armenia, The European Court of Human Rights (Fifth Section), sitting as a Chamber composed of:   Kateřina Šimáčková, President ,   Gilberto Felici,   Andreas Zünd,   Diana Sârcu,   Mykola Gnatovskyy,   Vahe Grigoryan,   Sébastien Biancheri, judges , and Martina Keller, Deputy Section Registrar , Having regard to: the applications (nos. 13721/23 and 34254/23) against the Republic of Armenia lodged with the Court under Article 34 of the Convention for the Protection of Human Rights and Fundamental Freedoms (“the Convention”) by Armenian nationals (“the applicants”) listed in the appendix on the various dates indicated therein; the decision to give notice to the Armenian Government (“the Government”) of the complaints concerning the excessive length of proceedings and, in respect of application no. 13721/23, the lack of an effective remedy for length-of-proceedings complaints; the parties’ observations; the decision to uphold the Government’s objection to examination of the applications by a Committee; Having deliberated in private on 28 April 2026, Delivers the following judgment, which was adopted on that date: INTRODUCTION 1 .     The cases concern the length of proceedings before the civil and administrative courts and the existence of effective domestic remedies by which compensation for the excessive length of proceedings may be sought. The applicants relied on Article 6 § 1 of the Convention. The applicants in application no. 13721/23 also invoked Article 13. THE FACTS 2.     The list of applicants and the relevant details of the applications are set out in the appended table. 3.     The Government were represented by their former Agent, Mr   Y.   Kirakosyan, and subsequently by Mr K. Andreasyan, Representative of the Republic of Armenia on International Legal Matters. 4.     The applicants were parties to civil and administrative proceedings which, in their view, were conducted in breach of the reasonable-time requirement under Article   6 §   1 of the Convention. Relevant dates and details are provided in the appended table. 5.     On 19 April 2014 the Civil Code was amended to include Articles   162.1 and 1087.2, which introduced the right to claim compensation in respect of non-pecuniary damage resulting from violations of the right to life, the prohibition of ill-treatment or the right to liberty committed by a State or local self-government body or its officials. On 21 December 2015 Article   162.1 was amended to extend that right to a broader range of Convention rights, including the right to a fair trial (see paragraph 6 below). The amendment entered into force on 1 January 2016. RELEVANT LEGAL FRAMEWORK AND PRACTICE         Domestic Law    The Civil Code 6 .     The relevant provisions of the Civil Code read as follows: Article 162.1. Definition of non-pecuniary damage and compensation for such damage “1. For the purposes of this Code, non-pecuniary damage means physical or mental suffering caused by a decision, action or inaction that interferes with a person’s pecuniary or non-pecuniary interests, whether inherent or granted by law, or violates that person’s pecuniary or non-pecuniary rights. 2. A person, or, in the event of his or her death or legal incapacity, his or her spouse, parent, adopter, child, adoptee, guardian or trustee, has the right to claim compensation in respect of non-pecuniary damage from the court through judicial proceedings, if it has been established by an investigating authority, a prosecutor or a court that as a result of a decision, action or inaction by a State or local self-government body or one of its officials, his or her fundamental rights guaranteed by the Constitution and the Convention for the Protection of Human Rights and Fundamental Freedoms have been violated, [including] ... (4) the right to a fair trial ...” Article 1087.2. The procedure and conditions for compensating for non-pecuniary damage arising from a violation of fundamental rights or an unjust conviction “1. The form, basis and amount of non-pecuniary damage suffered as a result of a violation of fundamental rights or an unjust conviction shall be determined in accordance with this Article and Article 162.1 of the present Code. 2. Non-pecuniary damage shall be compensated for, irrespective of any pecuniary damage subject to compensation. 3. Non-pecuniary damage shall be compensated for, regardless of whether the official who caused the damage is at fault. 4. Non-pecuniary damage shall be compensated for from the State budget... 5. The amount of compensation for non-pecuniary damage shall be determined by the court in accordance with the principles of reasonableness, equity and proportionality. 6. When determining the amount of compensation for non-pecuniary damage, the court shall take into account the nature, degree and duration of the physical or mental suffering, the consequences of the damage caused, the existence of fault when the damage was caused, the personal characteristics of the injured party, as well as other relevant circumstances. 7. The amount of compensation shall not exceed: ... (2) Two thousand times the fixed minimum wage [one thousand Armenian drams [1] ] in the case of violation of the rights specified in points 3 to 9 of part 2 of Article 162.1 of this Code. 8. In exceptional cases [2] , the amount of compensation for non-pecuniary damage may exceed the maximum limits provided for in part 7 of this Article if the damage caused has resulted in severe consequences. 9. A claim for compensation in respect of non-pecuniary damage may be submitted to the court either together with the claim to establish the violation of the right specified in part 2 of Article 162.1 of this Code, within one year from the moment the person becomes aware of the violation, or within one year from the moment the judicial act confirming the violation enters into legal force, or from the moment the person becomes aware of a decision not to initiate a criminal prosecution, [a decision] to terminate [a criminal prosecution], or [a decision] to discontinue criminal proceedings on grounds other than those qualifying as rehabilitative, provided that such a decision has not been quashed or appealed against. 10. The Republic of Armenia, or a municipality that has compensated for damage caused as a result of a decision, action or inaction of a State or local self-government body or one of its officials, has the right of recourse (regress) against the person in question in relation to the amount of compensation it has paid. The basis for bringing a recourse claim is the existence of fault on the part of the official from the State or local self-government body.”    The Civil Code of Procedure (2018) 7.     Article 102 of the Code provides that the State duty for an application comprising both pecuniary and non-pecuniary claims must be calculated and collected separately for each individual claim. 8 .     Article 109 of the Code provides that court fees (comprising the State duty and other expenses related to the proceedings) must be apportioned between the parties to the proceedings in proportion to the number of claims that have been allowed. 9 .     Article 112 of the Code provides that court fees related to lodging and examining appeals must be apportioned between the parties to the proceedings in accordance with the same rules.    The State Fees Act 10.     Section 8 of the Act provides that the rates of the State duty must be determined on the basis of the value of the property subject to appraisal, or in accordance with the base fee established by this Act. The base fee is set at 1,000 Armenian drams (AMD) [3] . 11 .     Section 9 of the Act provides that in respect of pecuniary claims, the State duty for lodging court applications and appeals is levied at 3%, 4% [4] or   5% [5] of the amount in dispute indicated in the applications and appeals lodged with a first-instance court, an appellate court or the Court of Cassation respectively. In respect of non-pecuniary claims, the State duty is 20, 30 or   40 times the base fee for applications and appeals lodged with a first ‑ instance court, an appellate court or the Court of Cassation respectively. 12 .     Section 21 of the Act provides that relief in respect of the State duty may include: exemption from payment, reduction of an amount or rate, postponement of payment deadlines, and waiver of or postponement of penalties for late payment. 13 .     Section 31(1)(c) of the Act provides that in relation to individuals or groups who are liable to pay the State duty, relief in that regard may be granted by the courts in specific cases set out in section 9 of the Act, on the basis of the parties’ financial circumstances.       DOmestic Practice    The Constitutional Court      Decision of the Constitutional Court of 3 March 2020 on the conformity with the Constitution of Article 1087.2 §§ 7 and 8 of the Civil Code, upon an application by the Yerevan First-Instance Court of General Jurisdiction (decision no. ՍԴՈ-1513) 14 .     In decision no. ՍԴՈ-1513 the Constitutional Court of Armenia observed that Article 1087.2 § 8, read in conjunction with Article 1087.2 §   7, provided that compensation in respect of non-pecuniary damage could exceed the statutory maximum only in “exceptional cases” involving “serious consequences”. The Constitutional Court held that any violation of fundamental rights or an unjust conviction was inherently exceptional, and therefore the harm done to each claimant was unique. Thus, claimants should not be required to prove the “extraordinary” nature of their suffering, nor should courts apply this vague criterion comparatively. Such a burden was disproportionate and impeded effective judicial protection. Nonetheless, additional legal thresholds for claims exceeding the upper limits for compensation were proportionate to the State’s interests. When seeking compensation which exceeded the upper limit, claimants had to demonstrate substantially different or more serious circumstances. The Constitutional Court held that the determination of “serious consequences” lay within the discretion of the court in each case; the court could decide whether the consequences arising from the damage sustained by a claimant were indeed serious, following a thorough assessment of all relevant factual circumstances and applying the criteria laid down in Article 1087.2 §§ 5 and 6 of the Code.      Decision of the Constitutional Court of 16 March 2021 on the conformity with the Constitution of section 9 of the Constitutional Act on the Judicial Code, upon an application by the Human Rights Defender (decision no. ՍԴՈ-1585) 15 .     In decision no. ՍԴՈ-1585 the Constitutional Court examined the question of whether section 9 of the Judicial Code – which provides that cases should be examined within a reasonable time and lays down criteria whereby the reasonableness of the length of proceedings is to be determined – complied with the Constitution. The Constitutional Court held, among other things, that in order to prevent possible breaches, the State should firstly put in place the necessary framework and procedures in order to ensure reasonable expedition, and secondly, in the case of a delay, provide an effective remedy. Having regard to a report prepared by the Supreme Judicial Council concerning the number of cases and the length of proceedings, as well as the Court’s judgments against Armenia, the Constitutional Court concluded that the situation was problematic. It noted that there could be various factors underlying the issue of the length of proceedings. One of the possible ways to improve the situation was to provide for a judge being responsible in the event of non-compliance with the reasonable ‑ time requirement (such as by assessing his or her work or subjecting him or her to a disciplinary measure). However, this was not a sustainable solution to tackle the problem. At the same time, given the courts’ workload, the State should ensure that judges were not overloaded, so that they could decide the cases within a reasonable time, but not at the cost of other requirements relating to fairness. The Constitutional Court noted that this could be achieved by simplifying the procedures before the courts, reducing the number of cases and recruiting more court staff. As regards the protection mechanisms against delays, the Constitutional Court noted that a compensatory remedy was available in Armenia (under Article 162.1 of the Civil Code), but did not address the constitutionality of that remedy, given that such a question had not been raised before it. As regards the lack of preventive mechanisms, and having agreed with the claimant in question that the existence of such mechanisms was important, the Constitutional Court held that while the State had to ensure a reasonable time frame for examining cases and preventing violations, the choice of the specific measures to achieve that goal was at the discretion of the legislature. Having concluded that Article 9 of the Judicial Code complied with the Constitution, the Constitutional Court noted that it was the duty of the legislature to provide for mechanisms which would ensure, in the most effective manner, the right to a trial within a reasonable time, in response to the issues highlighted in its decision.    Domestic case-law on claims for compensation in respect of non ‑ pecuniary damage under Article 162.1 § 2 (4) and Article   1087.2 of the Civil Code, relied on by the Government      Final judgments concerning compensation claims 16 .     By a judgment delivered on 7 September 2020 (case no.   ԵԴ/25468/02/19), the Yerevan First-Instance Court of General Jurisdiction (hereinafter “the Yerevan Court”) dismissed a claim for compensation alleging that the length of proceedings before the Administrative Court of Armenia had been excessive. The main proceedings, which had concerned a pecuniary claim brought against the claimant by the State, had lasted four and a half years at one level of jurisdiction, and it had taken the Administrative Court nearly two years to send the judgment to the claimant. The Yerevan Court dismissed the claim. It essentially found that the claimant had failed to submit sufficient evidence indicating that the adjournment of hearings had violated his right to a hearing within a reasonable time or that the hearings could reasonably have been scheduled earlier. Specifically, the claimant had provided audio-recordings for only seven out of the twelve court hearings, which had not been sufficient to determine the overall length of the proceedings, including the conduct of the parties. Furthermore, the recordings submitted had not revealed any undue adjournments or procedural delays. Similarly, the incomplete information prevented the court from fully assessing the complexity of the case. The Yerevan Court also dismissed the claimant’s assertion that the delayed service of the Administrative Court judgment had prejudiced his rights, firstly owing to lack of evidence, and secondly because the judgment had been rendered in his favour. The judgment of the Yerevan Court was upheld by higher courts, and the proceedings lasted one year and seven months across three levels of jurisdiction. 17 .     By a judgment delivered on 29 June 2021 (case no. ԵԴ/37503/02/19), the Yerevan Court dismissed a claim for compensation alleging that the length of proceedings before the Lori Regional Court had been excessive. The main proceedings, which had concerned a claim for partition of property, had been pending before the Lori Regional Court for over six years at the time the compensation claim was filed, nearly five of those six years pending the completion of an expert report. The Yerevan Court firstly noted that it should assess the length of proceedings solely from a procedural standpoint, without examining the lawfulness of the conduct of any specific judge. Having regard to the relevant criteria – namely the complexity of the case, the consequences of any delay for the claimant, the authorities’ efficiency, and the applicant’s own conduct – the court held that all hearings had been duly scheduled and, in some cases, adjourned for valid reasons such as evidence gathering or the parties’ requests, including those of the claimant. The claimant had failed to submit any evidence about her conduct in the proceedings or what had been at stake for her. Nor had she demonstrated that similar cases had been handled more swiftly. The judgment of the Yerevan Court was upheld by higher courts, and the proceedings lasted two years and five months across three levels of jurisdiction. 18 .     By a judgment delivered on 19 March 2021 (case no.   ԵԴ/31299/02/19), the Yerevan Court dismissed a claim for compensation alleging that the length of proceedings before the Administrative Court had been excessive. The main proceedings, which had concerned a claim against the State to compel it pay a pension for a specified period, had lasted five years and six months at only one level of jurisdiction, and it had taken the court almost a year to notify the claimant of its judgment. The compensation claim was examined by the Yerevan Court twice, following the case being remitted by an appellate court. During the second set of proceedings, the Yerevan Court noted that all hearings had taken place save for one, owing to the judge’s attendance at a training course. It observed that the matter had not been complex and that there had been no justification for the proceedings lasting more than five and a half years. However, the claimant had provided audio ‑ recordings for only 4 of the 14 hearings, which had impeded the court’s ability to assess his conduct fully. Whilst the recordings revealed that the case had resumed twice – giving rise to some concern – the court was unable to form a view on the conduct of the Administrative Court owing to the absence of formal decisions authorising those resumptions. With regard to the importance of the matter to the claimant, the court was unable to make any findings in the absence of evidence, particularly as the dispute concerned unpaid pension benefits for a period of one year and eight months, rather than the claimant’s pension entitlement or means of subsistence generally. An appeal by the claimant against the above-mentioned judgment was declared to have been lodged out of time. In total, the proceedings lasted four years and one month across three levels of jurisdiction. 19 .     By a judgment delivered on 21 July 2021 (case no. ԵԴ/1152/02/20), the Yerevan Court dismissed a claim for compensation alleging that the length of proceedings before the Administrative Court had been excessive. The main proceedings, which had concerned a claim for a land allocation decision, had been pending before that court for three years and two months at the time the compensation claim was filed. Some of the hearings had been scheduled with gaps of eight months to over a year between them. The Yerevan Court noted that all eight hearings scheduled by the Administrative Court (between 2017 and 2020) had taken place. As regards the complexity of the case and the claimant’s conduct, the claimant had failed to submit any evidence allowing the court to evaluate those criteria. The court concluded that in order to establish that his or her rights had been violated, a claimant had to provide factual evidence showing that the delay between the adjournment of a court hearing and the scheduling of the following hearing had clearly been unreasonable and solely due to the court, rather than external factors. In the absence of such evidence from the claimant, the court presumed that any delay had been reasonably justified for the proper administration of justice. The Civil Court of Appeal upheld that judgment, noting that the claimant, who bore the burden of proof and had limited herself to alleging a violation of her right to a hearing within a reasonable time, had failed to demonstrate that the case was not complex or should have been resolved more quickly. She had not shown that the duration of the case had caused her any harm or that the court’s timeline had been arbitrary rather than based on external factors. Furthermore, the claimant had not taken reasonable measures to shorten the duration of the case. The above-mentioned judgment was upheld by the Court of Cassation. The proceedings lasted two years and five months in total. 20 .     By a judgment delivered on 8 December 2021 (case no.   ԵԴ/31501/02/19 ), the Yerevan Court allowed a claimant’s compensation claim, finding that the length of the main proceedings in question, which had lasted five years in total across two levels of jurisdiction, had been excessive. It took into account the fact that the case had not been complex – it had concerned the claimant’s pension rights. There was no evidence that any delays had been caused by the claimant. Ultimately, the court ordered the State to pay the claimant AMD 300,000 and dismissed the remainder of his claim for compensation. The Yerevan Court ordered the defendant to reimburse the claimant the State duty that had already been paid in relation to the part of the claim which had been allowed. The claimant did not appeal against that judgment, and appeals by the defendant were dismissed. The appellate court noted, among other things, that the State should bear responsibility for the undue delays in the adjudication of the case, which had amounted to a violation of the claimant’s fundamental rights, regardless of the specific court or judicial errors involved. Moreover, the fact alone that the main proceedings had lasted five years constituted ample grounds to conclude that the claimant’s right to a fair trial and right to an effective remedy had been breached. The compensation proceedings lasted three years and two months across three levels of jurisdiction. 21 .     By a judgment delivered on 2 November 2023 (case no.   ԼԴ/6832/02/21), the Yerevan Court allowed a claimant’s compensation claim with regard to, inter alia , the length of criminal proceedings against her which had resulted in her being acquitted by the relevant trial court. The criminal proceedings against the claimant, including the investigation stage, had lasted just over four years across two levels of jurisdiction. Having regard to the claimant’s acquittal by the trial court, the Yerevan Court found that there had been a breach of her right to be presumed innocent, as well as her right to a fair trial. The court noted that the criminal proceedings against the claimant had lasted more than four years, during which time, as an accused, she had not been allowed to leave the country; this had caused her mental suffering. The court allowed the claim in part, awarding AMD 800,000 in compensation. The claimant was exempt from paying the State duty owing to her status as an acquitted person. The judgment was upheld by higher courts and the proceedings lasted around two years and ten months across three levels of jurisdiction. No information is available about the enforcement of the judgment. 22 .     In their assessment of the reasonable-time requirement, the domestic courts referred to Frydlender v. France ([GC], no. 30979/96, ECHR   2000 ‑ VII) and the related case-law. 23 .     According to the above-mentioned case-law examples, claimants were required to pay the State duty for both a claim seeking recognition of a violation of their fundamental rights (a non-pecuniary claim) and an ancillary claim for compensation (a pecuniary claim).      Judgments concerning compensation claims still pending before various courts 24.     The Government also submitted nine other cases in which courts had either dismissed or accepted in part compensation claims alleging a breach of the reasonable-time requirement. All of those cases were pending before various courts on 2 May 2025, the date when the Government submitted their observations. 25 .     Case no. ԵԴ/4961/02/18: Although the claimant’s compensation claim had been allowed in part and an appeal on points of law which he had lodged had been rejected by a final decision of the Court of Cassation, the relevant compensation proceedings were apparently still pending before the Court of Cassation as of 7 March 2023 because an appeal on points of law had been lodged by the defendant. At that point the proceedings had been ongoing for five years and five months in total. 26 .     Case no. ԵԴ/25302/02/19: The compensation proceedings were still pending before the Court of Cassation on 7 March 2023, and had been ongoing for three years and seven months in total. 27 .     Case no. ԵԴ/18511/02/21: The compensation proceedings were still pending before the Court of Cassation, and had been ongoing for four years in total. 28.     Case no. ԵԴ/29755/02/21: The information available indicates that an appeal by the claimant was rejected by the relevant appellate court on 19   June   2025, but it is unclear if an appeal on points of law has been lodged. The compensation proceedings had been ongoing for nearly four years across two levels of jurisdiction, and for three of those four years the proceedings had been before the first-instance court. 29 .     Case no. ԵԴ/6426/02/22: The compensation proceedings were still pending before the appellate court, and the proceedings had been ongoing for two years and nine months in total. 30 .     Case no. ԵԴ/25942/02/22: The case was pending before the first ‑ instance court. 31 .     Case no. ԵԴ/54146/02/22: The defendant had lodged an appeal on points of law and the case was pending before the Court of Cassation. As of 10   June 2025 the proceedings had been ongoing for two years and eight months. 32 .     Case no. ԵԴ/64639/02/22: The compensation proceedings were still pending before the appellate court, and the proceedings had been ongoing for approximately two and a half years in total. 33 .     Case no. ԵԴ2/44039/02/23: The compensation proceedings were still pending before the Court of Cassation as of 21 June 2025, and the proceedings had been ongoing for approximately one and a half years in total. THE LAW Preliminary issues    Joinder of the applications 34.     Having regard to the similar subject matter of the applications, the Court finds it appropriate to examine them jointly in a single judgment.    Locus standi (application no. 13721/23) 35.     The Court notes that the applicant L. Hakobyan in application no.   13721/23 died on 20 September 2024, while the case was pending before the Court. Her daughter, the applicant A. Hakobyan, who is her heir, informed the Court that she wished to pursue the application lodged by her mother. 36.     The Government contended that the applicant A. Hakobyan had not provided an inheritance certificate to substantiate her legal standing, and in any event, the complaint raised in the application concerned non ‑ transferable rights. They invited the Court to strike the application out of its list of cases as regards the applicant L. Hakobyan. 37.     Having regard to the circumstances of the present case and the documents submitted by the applicant A. Hakobyan, the Court accepts that as the heir of the late applicant L. Hakobyan, she has a legitimate interest in pursuing the application in her mother’s stead (see, among other authorities,   Horváthová v. Slovakia , no. 74456/01, § 26, 17 May 2005, and   Benyaminson v.   Ukraine , no. 31585/02, § 83, 26 July 2007).        ALLEGED VIOLATION OF ARTICLE 6 § 1 OF THE CONVENTION 38.     The applicants complained of the excessive length of proceedings before the civil and administrative courts. They relied on Article 6 § 1 of the Convention, which, in so far as relevant, reads as follows: “1. In the determination of his civil rights and obligations ... everyone is entitled to a ... hearing within a reasonable time by [a] ... tribunal ...”    Admissibility      The parties’ submissions    The Government 39 .     The Government argued that the applicants had failed to exhaust available domestic remedies. Specifically, Articles 162.1 and 1087.2 of the Civil Code had introduced an effective legal remedy by which allegations of a violation of the reasonable-time requirement under Article 6 § 1 could be raised. Although in Fil LLC v. Armenia (no. 18526/13, 29 January 2019) the Court had found a violation of Article 13 in conjunction with Article 6 § 1 owing to the absence of domestic remedies for complaints relating to the length of proceedings (§§ 48-51), the domestic law and practice had evolved since then. In support of their argument, the Government submitted 15 examples from domestic case ‑ law (outlined in paragraphs 16-33 above) where the civil courts had examined compensation claims lodged under Article 162.1 § 2 (4) and Article   1087.2 of the Civil Code in relation to allegations that the length of proceedings had been excessive. The Government claimed that around 58% of cases concerning compensation in respect of non-pecuniary damage lasted 3 years across three levels of jurisdiction. 40 .     The Government pointed out that the Constitutional Court, in a relevant decision, had also observed that the procedure in question had been incorporated into the domestic legal system as a remedy for length ‑ of ‑ proceedings complaints (see paragraph 15 above). The Government asserted that as provided for by Article 1087.2 § 9 of the Code, claimants could seek recognition of a breach of their right to a hearing within a reasonable time and simultaneously make a claim for compensation. The Government argued that even though there was a cap on the amount of compensation that could be claimed, the domestic courts were to consider a wide range of circumstances – they referred to Article 1087.2 §§ 5 and 6 of the Code – when determining the amount of such an award, ensuring that any decision on compensation was fair and proportionate. The Government contended that the applicants had thus failed to avail themselves of the remedy in question.    The applicants 41 .     The applicants in application no. 13721/23 contested the Government’s objection by referring to the Court’s findings in Fil   LLC , arguing that the domestic legal system in Armenia did not provide for any available and effective remedy for length-of-proceedings complaints in line with the Court’s case-law. They argued that the remedy in question did not satisfy the criteria established by the Court in its relevant case-law pertaining to the effectiveness of remedies for complaints concerning the excessive length of proceedings. The applicants seemed to suggest that the proceedings before civil courts in Armenia were too long, thereby affecting the effectiveness of any such remedy. They had therefore lacked any available and effective domestic remedy for the purposes of the exhaustion rule. 42 .     The applicants in application no. 34245/23 similarly objected to the Government’s non-exhaustion plea. They contested the effectiveness of the civil remedy suggested by the Government and referred to the Court’s findings in the above-cited case of Fil LLC and Vassilyan and Others v.   Armenia ([Committee], nos. 20193/15 and 2 others, 23 June 2022). As regards the domestic case-law examples submitted by the Government, they argued that the courts’ practice had not been consistent: the courts had either made minimal awards or had rejected the compensation claims in full, without applying the related Convention principles. The applicants took issue with the length of the compensation proceedings, which in some cases had lasted more than four years. They pointed out that, for instance, in case no.   ԵԴ/4961/02/18, the compensatory proceedings had lasted even longer than the main proceedings, and the domestic courts had found the length of the main proceedings problematic and had made an award in favour of the claimant (see paragraph 25 above). The applicants argued that the case-law examples submitted showed that the domestic courts had been reluctant to grant compensation claims. As regards the few case-law examples where such claims had been allowed, the reasoning of the courts had been inconsistent. The domestic courts had failed to carry out any meaningful assessment of the reasonable-time requirement in compliance with the criteria established by the Court, and their reasoning had either been lacking or overly formalistic. The applicants disputed the existence of settled domestic practice because most of the cases referred to by the Government had not even been concluded by a final decision and were still pending before various courts. The applicants concluded by submitting that the remedy in question was inadequate, inaccessible in practice and incapable of securing redress.      The Court’s assessment    General principles 43 .     The obligation provided for under Article 35 § 1 of the Convention requires only that an applicant should have normal recourse to remedies likely to be effective, adequate and accessible. In particular, the only remedies that the Convention requires to be exhausted are those that relate to the breaches alleged and are at the same time available and sufficient. The existence of such remedies must be sufficiently certain not only in theory but also in practice, failing which they will lack the requisite accessibility and effectiveness (see Sejdovic v. Italy [GC], no. 56581/00, § 45, ECHR 2006-II, and Scordino v. Italy (no. 1) [GC], no. 36813/97, § 142, ECHR 2006 ‑ V). 44.     With regard to the reasonable-time requirement, a remedy is “effective” in that it allows for an earlier decision by the courts to which the case has been referred or for the aggrieved party to be given adequate compensation for the delays that have already occurred (see Scordino , cited above, § 195; Sürmeli v. Germany [GC], no. 75529/01, § 99, ECHR   2006 ‑ VII; and Rutkowski and Others v. Poland , nos. 72287/10 and   2   others, § 173, 7 July 2015). 45 .     The best solution in absolute terms is indisputably, as in many spheres, prevention (see Scordino , § 183, and Fil LLC , § 47, both cited above). However, States may also choose to introduce only a compensatory remedy, without that remedy being regarded as ineffective (see Fil LLC , cited above, § 47, and Balakchiev and Others v. Bulgaria (dec.), no. 65187/10, §   57, 18 June 2013, with further references). 46 .     In the judgment in Scordino (cited above), the Court set key criteria for verifying the effectiveness of a compensatory remedy for excessively lengthy judicial proceedings. These criteria are as follows (§§ 195-207): (i)     the procedural rules governing an action for compensation must conform to the principle of fairness guaranteed by Article 6 of the Convention; (ii)     an action for compensation must be heard within a reasonable time; (iii)     the rules regarding legal costs must not place an excessive burden on litigants where their action is justified; (iv)     the level of compensation must not be unreasonable in comparison with the awards made by the Court in similar cases; (v)     the compensation must be paid promptly and generally no later than six months after the date on which the decision awarding compensation becomes enforceable. 47 .     The Court further reiterates that a remedy available to a litigant at domestic level for raising a complaint about the length of proceedings is “effective” within the meaning of Article 35 § 1 of the Convention only if it is capable of covering all stages of the proceedings complained of and thus, in the same way as a decision given by the Court, of taking into account their overall length (see Kirinčić and Others v. Croatia , no. 31386/17, §   110, 30   July 2020, with further references). 48 .     Where a State has taken a significant step by introducing a compensatory remedy, the Court must leave a wider margin of appreciation to the State to allow it to organise the remedy in a manner that is consistent with its own legal system and traditions and with the standard of living in the country concerned. The Court is required to verify whether the way in which the domestic law is interpreted and applied produces consequences that are consistent with the principles of the Convention, as interpreted in the light of the Court’s case-law. The principle of subsidiarity does not mean renouncing all supervision of the result obtained from using domestic remedies, as the Convention is intended to guarantee not theoretical or illusory rights, but rights that are practical and effective ( see Cocchiarella v. Italy [GC], no.   64886/01, §§ 80-83, ECHR 2006-V, and Scordino , cited above, §§   189 ‑ 192). 49 .     The mere fact that the compensation awarded to the applicants at the domestic level does not correspond to the amounts awarded by the Court in comparable cases does not render the remedy ineffective (see Kaić and Others v.   Croatia , no. 22014/04, 17 July 2008, § 39, with further references). 50.     With regard to pecuniary damage, the domestic courts are clearly in a better position to determine its existence and quantum (see Scordino , cited above, § 203). The situation is different as regards non-pecuniary damage; the reasoning of the courts in such matters should be based on the strong but rebuttable presumption that excessively long proceedings would occasion non ‑ pecuniary damage (see Martins Castro and Alves Correia de Castro v.   Portugal , no. 33729/06, § 54, 10 June 2008). 51 .     The Court accepts that, in some cases, the length of proceedings may result in only minimal non-pecuniary damage or no non-pecuniary damage at all (see Cocchiarella , cited above, §§ 96-97). The domestic courts will then have to justify their decision by giving sufficient reasons (see Scordino , cited above, § 204, and Martins Castro and Alves Correia de Castro , cited above, §   54).    Application of the above principles to the present case 52 .     The Court notes that it has previously rejected objections of non ‑ exhaustion raised by the Government in cases concerning the length of proceedings (see Fil LLC , cited above, §§ 42 and 48-51). Specifically, in Fil   LLC the Court dismissed the Government’s assertion that there was a procedure available to the applicant company which was capable of expediting pending civil proceedings (ibid., § 48). In addition, the Government did not suggest any procedure by which redress could be sought for the delays which had already occurred (ibid., § 49). 53.     In a number of ca