Lakatos and Others v. Romania

FOURTH SECTION

Application no. 12426/22 Romică-Ciprian LAKATOS against Romania and 18 other applications

(see appended table)

The European Court of Human Rights (Fourth Section), sitting on 21 May 2026 as a Committee composed of:

Anne Louise Bormann , President , András Jakab, Corinna Wissels , judges ,

and Viktoriya Maradudina, Acting Deputy Section Registrar,

Having regard to the above applications against Romania lodged with the Court under Article 34 of the Convention for the Protection of Human Rights and Fundamental Freedoms (“the Convention”) on the various dates indicated in the appended table,

Having regard to the observations submitted by the respondent Government and the observations in reply submitted by the applicant,

Having deliberated, decides as follows:

The list of applicants is set out in the appended table.

The applicants’ complaints under Article 3 of the Convention concerning the inadequate conditions of detention were communicated to the Romanian Government (“the Government”). In some applications, the applicants raised additional complaints under various provisions of the Convention.

Having regard to the similar subject matter of the applications, the Court finds it appropriate to examine them jointly in a single decision.

The applicants complained principally of the inadequate conditions of their detention. They relied on Article 3 of the Convention.

Having examined all the material before it, the Court considers that for the reasons stated below, the present complaints are inadmissible.

The Government argued that the applicants had failed to exhaust the available effective remedies for their complaints about the inadequate conditions of their detention, as the complaint with the judge responsible for supervising the deprivation of liberty ( plângerea în fața judecătorului de supraveghere a privării de libertate ), provided for by Article 56 of Law no. 254/2013, had become an effective remedy for grievances similar to those of the applicants.

The Court recalls that in Văscăuțanu v. Romania (dec.), no. 10120/23, §§ 47–59, 18 November 2025, it held that the remedy, which consists of lodging a complaint with the judge responsible for supervising the deprivation of liberty ( plângerea în fața judecătorului de supraveghere a privării de libertate ), provided for by Article 56 of Law no. 254/2013, constituted, as of 6 April 2023, an effective remedy enabling individuals who allege that they are being held in inadequate conditions of detention to put an end to their situation that they denounced as being contrary to Article 3 of the Convention.

In light of all the material in its possession, the Court observes that the applicants, who allege that they are being held in inadequate conditions of detention, did not indicate that they pursued the available remedy before the domestic courts (see Văscăuțanu , cited above, § 65). Therefore, their complaints in that regard must be dismissed for failure to exhaust domestic remedies.

The Government also invoked other grounds of inadmissibility to argue that the present complaints must be rejected. Since it has already upheld the Government’s objection on the non-exhaustion of domestic remedies, the Court does not consider it necessary to examine further additional arguments raised by the Government.

In view of the above, the Court finds that the applicants’ complaints concerning the periods of their detention set out in the appended table must be rejected for failure to exhaust the domestic remedy laid down in Article 56 of Law no. 254/2013, in accordance with Article 35 §§ 1 and 4 of the Convention.

Some applicants also raised other complaints under various articles of the Convention.

The Court has examined the applications listed in the appended table and considers that, in the light of all the material in its possession and in so far as the matters complained of are within its competence, these complaints either do not meet the admissibility criteria set out in Articles 34 and 35 of the Convention or do not disclose any appearance of a violation of the rights and freedoms enshrined in the Convention or the Protocols thereto.

It follows that this part of the applications must be rejected in accordance with Article 35 § 4 of the Convention.

For these reasons, the Court, unanimously,

Decides to join the applications;

Declares the applications inadmissible.

Done in English and notified in writing on 11 June 2026.

Viktoriya Maradudina Anne Louise Bormann Acting Deputy Registrar President

APPENDIX

List of applications raising complaints under Article 3 of the Convention

(inadequate conditions of detention)

No.

Application no.

Date of introduction

Applicant’s name

Year of birth

Representative’s name and location

Facility

Start and end date

Duration

12426/22

22/02/2022

Romică-Ciprian LAKATOS

1988

Gherla, Baia Mare and Bistrița Prisons

03/04/2020

pending

More than 5 year(s) and 10 month(s) and 25 day(s)

13522/22

10/02/2022

Lucian Adrian BONCU

1978

Pașca Mihai-Lucian

Timisoara

Timișoara and Oradea Prisons

10/02/2022

pending

More than 4 year(s) and 18 day(s)§

16004/22

02/08/2022

Ştefan DANI

1983

Gherla, Oradea, Satu Mare, Baia Mare, Bistrița, Deva and Iași Prisons; Dej Prison Hospital

18/12/2020

pending

More than 5 year(s) and 2 month(s) and 10 day(s)

16506/22

18/04/2022

Valentin IACOB

1974

Iași Prison

23/12/2019

pending

More than 6 year(s) and 2 month(s) and 5 day(s)

20068/22

08/06/2022

Florin PUZSA

1973

Baia Mare, Deva and Gherla Prisons

18/04/2018

pending

More than 7 year(s) and 10 month(s) and 10 day(s)

32112/22

22/08/2022

Costel IORGA

1965

Târgu Ocna Prison Hospital; Iași, Bucharest-Rahova, Botoșani and Găești Prisons

23/12/2019

pending

More than 6 year(s) and 2 month(s) and 9 day(s)

34979/22

09/08/2022

Alexandru-Marian MITU

1976

Constanța Police Detention facility, Poarta Albă (Constanța), Slobozia and Arad Prisons

13/03/2019

pending

More than 6 year(s) and 11 month(s) and 20 day(s)

36005/22

22/09/2022

Remus VEREŞ

1979

Oradea Prison

04/09/2019

pending

More than 6 year(s) and 6 month(s) and 1 day(s)

37191/22

03/04/2023

Iulian-Cosmin ATĂNĂSOAEI

1991

Bacău County Police Station; Bacău and Botoșani Prisons

19/01/2022

pending

More than 4 year(s) and 1 month(s) and 14 day(s)

39073/22

04/08/2022

Laurenţiu-Vasile DUMITRU

1989

Bucharest Police detention facility no. 4; Rahova and Jilava Prisons

08/07/2020

pending

More than 5 year(s) and 7 month(s) and 25 day(s)

39436/22

20/09/2022

Iulian CÎTEA

1970

Gherla Prison

06/07/2017

pending

More than 8 year(s) and 7 month(s) and 27 day(s)

41398/22

18/10/2022

Costel AVĂTĂMĂNIŢEI

1985

Botoșani and Arad Prisons

05/01/2019 to

01/04/2019

2 month(s) and 28 day(s)

Botoșani and Arad Prisons

08/11/2019

pending

More than 6 year(s) and 3 month(s) and 25 day(s)

45026/22

24/10/2022

Tiberius Virgil STOICA

1984

Arad, Oradea, Craiova and Iași Prisons

13/11/2020

pending

More than 5 year(s) and 3 month(s) and 20 day(s)

45547/22

20/10/2022

Petre OSMAN

1981

IPJ Olt Police Station; Craiova, Mărgineni and Giurgiu Prisons

21/08/2010

pending

More than 15 year(s) and 6 month(s) and 12 day(s)

46423/22

12/06/2023

Alexandru-Mircea DUMITRACHE

1986

Bucharest-Rahova, Giurgiu, Mărgineni and Ploiești Prisons

06/09/2016

pending

More than 9 year(s) and 5 month(s) and 27 day(s)

46831/22

28/11/2022

Marius

RUSU

1988

Aiud Prison

23/04/2021

pending

More than 4 year(s) and 10 month(s) and 3 day(s)

48002/22

17/01/2023

Vasile-Ioan

POP

1977

Gherla and Baia Mare Prisons

18/10/2018

pending

More than 7 year(s) and 4 month(s) and 8 day(s)

51836/22

12/12/2022

Nicolae-Ionuţ FERARU

1988

Vaslui County Police Station; Giurgiu, Iași, Vaslui and Galați Prisons

14/09/2016

pending

More than 9 year(s) and 5 month(s) and 19 day(s)

56571/22

29/11/2022

Cosmin ROSTAS

1990

Sălaj and Alba Counties Police Stations; Gherla, Oradea and Bistrița Prisons

09/09/2021

pending

More than 4 year(s) and 5 month(s) and 24 day(s)