Zodilă-Cristic and Others v. Romania
Inadmissible
Berörda konventionsartiklar
FOURTH SECTION
Application no. 36321/22 Nicu-Aurel ZODILĂ-CRISTIC against Romania and 18 other applications
(see appended table)
The European Court of Human Rights (Fourth Section), sitting on 4 June 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”).
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 applications 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 applications must be dismissed for failure to exhaust domestic remedies.
The Government also invoked other grounds of inadmissibility to argue that the present applications 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 the remaining arguments raised by the Government.
In view of the above, the Court finds that the applicants’ complaints concerning the periods 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.
For these reasons, the Court, unanimously,
Decides to join the applications;
Declares the applications inadmissible.
Done in English and notified in writing on 25 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
Facility
Start and end date
Duration
36321/22
15/07/2022
Nicu-Aurel ZODILĂ-CRISTIC
1996
Timişoara, Deva and Arad Prisons
23/12/2019
pending
More than 6 year(s) and 2 month(s) and 3 day(s)
41402/22
09/11/2022
Constantin-Mircea CRIŞAN
1976
Aiud and Arad Prisons
26/11/2009
pending
More than 14 year(s) and 4 month(s) and 22 day(s)
41712/22
18/10/2022
Cristian ISTRATE
1991
Arad Prison
18/06/2015
pending
More than 8 year(s) and 9 month(s) and 30 day(s)
42682/22
12/12/2022
Marin DRAFI
1978
Gherla, Oradea and Timișoara Prisons
08/06/2023
pending
More than 10 month(s) and 18 day(s)
42783/22
28/09/2022
Mihai MIŞIRELICU
1983
Tulcea Prison
23/12/2019
pending
More than 4 year(s) and 4 month(s) and 21 day(s)
56193/22
09/01/2023
Mircea AVROIAN
1986
Iasi, Mărgineni, Galați, Vaslui and Craiova - Pelendava Prisons
15/07/2019
pending
More than 5 year(s) and 3 month(s) and 14 day(s)
56767/22
24/02/2023
Constantin-Cristi POPA
1989
Mioveni and Craiova Prisons
08/04/2022
pending
More than 2 year(s) and 7 month(s) and 20 day(s)
57563/22
13/01/2023
Vlăduț CRUPĂ
1996
Botoșani, Gherla and Mărgineni Prisons
11/01/2020
pending
More than 4 year(s) and 3 month(s) and 6 day(s)
57589/22
07/02/2023
Stelică MĂGĂRIŢĂ
1998
Brăila and Galați Prisons
16/12/2018
pending
More than 5 year(s) and 10 month(s) and 16 day(s)
57783/22
09/06/2023
Mihail FENEŞAN
1975
Bucharest - Rahova and Oradea Prisons
13/05/2022
pending
More than 2 year(s) and 5 month(s) and 12 day(s)
13991/23
26/04/2023
Nicuşor-Valentin ENE
1996
Craiova Prison
12/03/2020
pending
More than 4 year(s) and 5 month(s) and 21 day(s)
16218/23
12/06/2023
Ionuţ-Ion CALOTĂ
1985
Giurgiu Prison
05/12/2019
Pending
More than 5 year(s)
19562/23
14/07/2023
Péter-Levente KERESZTES
1971
Târgu Mureş and Oradea Prisons
11/08/2021
pending
More than 3 year(s) and 27 day(s)
20774/23
24/07/2023
Iosif-Lucian BOZSODI
1994
Gherla, Bistriţa and Baia Mare Prisons
11/02/2020
pending
More than 4 year(s) and 9 month(s) and 24 day(s)
21807/23
23/06/2023
Marius GULIE
1988
Craiova and Drobeta-Turnu Severin Prisons
23/12/2019
pending
More than 4 year(s) and 11 month(s) and 12 day(s)
26269/23
24/07/2023
Augustin-Marian POPESCU
1986
Bucharest - Jilava Prison
23/12/2019
pending
More than 4 year(s) and 11 month(s) and 10 day(s)
29057/23
05/09/2023
Eugen ŞERBAN
1957
Bucharest - Jilava and Timişoara Prison Hospitals; Drobeta-Turnu Severin Prison
07/10/2022
pending
More than 2 year(s) and 1 month(s) and 26 day(s)
29844/23
28/08/2023
Vasile OPREA
1961
Bucharest - Rahova and Mioveni Prisons
23/12/2019
pending
More than 4 year(s) and 11 month(s) and 12 day(s)
41917/23
05/01/2024
Ion GAIDAŞ
1963
Bucharest - Jilava Prison
28/01/2025
pending
More than 1 month(s) and 24 day(s)