CCPR/C/144/D/3083/2017

GE.25-13043 (E) 230925 240925

Human Rights Committee

Decision adopted by the Committee under the Optional

Protocol, concerning communication No. 3083/2017*, **

Communication submitted by:

A.P. (represented by counsel, Alexey Laptev)

Alleged victim:

The author

State Party:

Russian Federation

Date of communication:

28 February 2017 (initial submission)

Document references:

Decision taken pursuant to rule 92 of the

Committee’s rules of procedure, transmitted to

the State Party on 22 December 2017

Date of adoption of decision:

17 July 2025

Subject matter:

Fair trial and life imprisonment

Procedural issues:

Abuse of the right of submission; exhaustion of

domestic remedies; non-substantiation

Substantive issues:

Fair trial; legal assistance

Article of the Covenant:

14 (1), (3) (b), (d) and (g) and (5)

Articles of the Optional Protocol:

2, 3 and 5

1.

The author of the communication is A.P., a national of the Russian Federation born in

1986. He claims that the State Party has violated his rights under article 14 (1) and (3) (d)

and (g) of the Covenant. The Optional Protocol entered into force for the State Party on

1 January 1992. The author is represented by counsel.

Facts as submitted by the author

2.1

On 27 April 2006, the author was arrested on suspicion of committing an act of arson

in May 2005 in a shopping centre in the city of Ukhta, in the Komi Republic, that resulted in

the deaths of 25 people. Upon his arrest, he informed the police that he would like to retain

the services of two lawyers. One of the two lawyers was allowed to meet with the author on

28 April 2006, and the other on 2 May 2006. On 29 April 2006, the Ukhta Federal Court

authorized the author’s detention until 2 May 2006. On 2 May 2006, the same court

authorized the author’s detention pending trial.

* Adopted by the Committee at its 144th session (23 June–17 July 2025).

** The following members of the Committee participated in the examination of the communication:

Wafaa Ashraf Moharram Bassim, Rodrigo A. Carazo, Yvonne Donders, Carlos Ramón Fernández

Liesa, Laurence R. Helfer, Konstantin Korkelia, Dalia Leinarte, Bacre Waly Ndiaye, Hernán Quezada

Cabrera, Akmal Saidov, Ivan Šimonović, Soh Changrok, Teraya Koji, Hélène Tigroudja and Imeru

Tamerat Yigezu.

United Nations

CCPR/C/144/D/3083/2017

International Covenant on

Civil and Political Rights

Distr.: General

24 September 2025

Original: English

CCPR/C/144/D/3083/2017

2

GE.25-13043

2.2

On 6 May 2006, the case investigator called in both lawyers and attempted to question

them as witnesses, asking questions regarding information that they had obtained in their

meetings with the author. Both lawyers refused to answer the investigator’s questions, citing

their status as the author’s defence counsel. Nevertheless, on 10 May 2006, the investigator

issued an order barring both lawyers from continuing with the author’s defence due to their

status as witnesses in the criminal case. On an unspecified date, an ex officio lawyer was

appointed by the investigator to take over the defence of the author. On 18 and 19 May 2006,

the investigator pressured the author into signing a confession, which he eventually did and

then later retracted. This confession was documented in the presence of the ex officio lawyer

and used against the author during the trial.

2.3

On 7 May 2006, the lawyer assigned to represent the author’s co-defendant recused

himself from further defending his client because he thought that the latter was incriminating

himself. However, in accordance with article 49 (7) of the Code of Criminal Procedure, such

recusals are not allowed in criminal cases. Despite this, the case investigator unlawfully

replaced the lawyer representing the author’s co-defendant with another, which resulted in

the violation of the rights of the author’s co-defendant, as well as the rights of the author

himself.

2.4

On 7 November 2007, during the trial before the Supreme Court of the Komi Republic,

the author submitted a complaint against the decision of the investigator barring the author’s

two lawyers from the case. On 8 November 2007, the Court held that the questioning of the

lawyers by the case investigator had violated article 56 (3) of the Code of Criminal

Procedure,1 and reinstated both lawyers as the author’s defence counsel in the case.

2.5

On 26 June 2008, a panel of three judges of the Supreme Court of the Komi Republic

acquitted the author and his co-defendant of all charges. The Court also issued a special ruling

drawing the attention of the prosecutor’s office to several procedural violations that had taken

place during the investigation, including the illegal barring of the author’s lawyers from the

case.

2.6

On 30 October 2008, upon appeal from the prosecutor’s office, the Supreme Court of

the Russian Federation quashed the acquittal and sent the case for a retrial before the Supreme

Court of the Komi Republic by a different panel of judges. The Supreme Court of the Russian

Federation held that the trial court’s conclusions were not supported by the evidence

examined during the trial and that it had not taken into consideration certain circumstances

that could have significantly affected its conclusion.

2.7

On 17 June 2009, a new panel of judges of the Supreme Court of the Komi Republic

found the author and his co-defendant guilty of arson and several other crimes and sentenced

them to life imprisonment.

2.8

On 26 October 2009, the Criminal Division of the Supreme Court of the Russian

Federation, acting as a court of cassation, amended the verdict by excluding the finding of

guilt on the charge of “premeditated murder” but upheld the trial court’s sentence of life

imprisonment. On 26 October 2016, the author filed an appeal to the Supreme Court of the

Russian Federation for a supervisory review, which was dismissed on 28 December 2016.

Between 2011 and 2016, the author submitted numerous complaints to the Prosecutor’s

Office of the Komi Republic and to the Office of the Prosecutor General of the Russian

Federation, but all his complaints were dismissed.2 The author therefore contends that he has

exhausted all available and effective domestic remedies.

Complaint

3.1

The author submits that he was denied a fair trial by a competent and impartial tribunal,

as guaranteed by article 14 (1) of the Covenant. He argues that: (a) the Supreme Court of the

1 Article 56 (3) of the Code of Criminal Procedure states that the defence counsel for a suspect or

accused person may not be questioned as a witness about circumstances that have become known to

him or her in connection with the seeking of legal assistance from him or her or in connection with

the provision of legal assistance.

2 The author provides copies of letters received from the Prosecutor’s Office of the Komi Republic and

from the Office of the Prosecutor General of the Russian Federation.

CCPR/C/144/D/3083/2017

GE.25-13043

3

Komi Republic did not follow the instructions of the cassation court for the retrial, by failing

to request necessary documents, to question forensic experts, and to conduct new forensic

examinations; (b) during the retrial, the Supreme Court of the Komi Republic court

insufficiently substantiated its decision that the conclusions from the polygraph tests were

unreliable; (c) the Supreme Court of the Komi Republic did not ensure that the author and

his co-defendant had the right to determine the composition of the court for the retrial, in

violation of article 30 of the Code of Criminal Procedure;3 (d) the domestic courts ignored

the forgery of documents during the pretrial investigation (for example, the same forensic

experts and witnesses were recorded as having participated at the same time in different

investigative activities in different locations); (e) the courts allowed the prosecution to

introduce evidence that had been obtained unlawfully or lacked credibility, such as

wiretappings of the author’s phone calls from detention facilities and contradicting

testimonies of witnesses; and (f) some of the charges against the author were based on an

incorrect classification of his actions.

3.2

The author claims that, by removing the two original lawyers from his case, the

investigative authorities prevented him from defending himself through legal assistance of

his own choosing, in violation of his rights under article 14 (3) (d) of the Covenant.

3.3

The author also claims that, by admitting as evidence the confession that he gave

under duress during the pretrial investigation, the domestic courts violated his rights under

article 14 (3) (g) of the Covenant.

State Party’s observations on admissibility and the merits

4.1

By note verbale dated 27 August 2018, the State Party submitted its observations on

the admissibility and merits of the communication.

4.2

With regard to admissibility, the State Party notes that the Criminal Division of the

Supreme Court of the Russian Federation, acting as a court of cassation, amended the verdict

of the Supreme Court of the Komi Republic on 26 October 2009, while the author submitted

his communication to the Committee on 28 February 2017. Thus, the State Party argues, the

author submitted his communication seven years and four months after exhausting domestic

remedies, which constitutes an abuse of the right of submission under rule 99 (c) of the

Committee’s rules of procedure. The State Party also notes that the author submitted his first

appeal for a supervisory review to the Presidium of the Supreme Court of the Russian

Federation on 17 June 2015, that is, more than five years and seven months after the decision

of the cassation court. The State Party considers that there are no indications of any

circumstances justifying such a delay, and, therefore, the author’s communication is

inadmissible under article 3 of the Optional Protocol.

4.3

The State Party further submits that the author’s claim under article 14 (1) of the

Covenant is manifestly unfounded. According to the State Party, the author’s claims relate

essentially to the evaluation of facts and evidence and the application of domestic law by the

domestic courts. It notes that it is generally for the courts of States Parties to review facts and

evidence, or the application of domestic legislation, in a particular case, unless it can be

shown that such evaluation or application was clearly arbitrary or amounted to a manifest

error or denial of justice. The State Party argues that the author has failed to sufficiently

substantiate this claim, and, therefore, it is inadmissible under article 2 of the Optional

Protocol.

4.4

With regard to the author’s claims under article 14 (3) (d) and (g) of the Covenant, the

State Party notes that the author did not raise them in his cassation appeal to the Criminal

Division of the Supreme Court of the Russian Federation. According to the State Party, in

his appeals for a supervisory review to the Presidium of the Supreme Court of the Russian

3 The author submits that, according to article 30 of the Code of Criminal Procedure, the composition

of the court could have been formed by a panel of three judges, by a single judge, or by a single judge

and a panel of 12 jurors.

CCPR/C/144/D/3083/2017

4

GE.25-13043

Federation,4 the author also failed to raise these claims as submitted in his communication to

the Committee. In view of the above, the State Party argues that the author has not exhausted

all available domestic remedies with regard to his claims under article 14 (3) (d) and (g) of

the Covenant and, therefore, they are inadmissible in accordance with article 5 (2) (b) of the

Optional Protocol.

4.5

With regard to the merits, the State Party notes that the author’s claim that the

Supreme Court of the Komi Republic did not follow the instructions of the cassation court

for the retrial has already been the subject of a cassation review by the Criminal Division of

the Supreme Court of the Russian Federation and found to be unsubstantiated. In its cassation

ruling of 26 October 2009, the cassation court concluded that, in the previous cassation ruling,

of 30 October 2008, it had been stated that, if needed, the trial court should discuss the

necessity of questioning experts in court to have them explain their conclusions and of

appointing additional expert examinations. The State Party notes that two forensic experts

were questioned during the retrial, and the trial court saw no grounds for requesting additional

expert examinations.

4.6

With regard to the conclusions from the polygraph tests, the State Party submits that,

as follows from the judgment of 17 June 2009, the trial court found that the conclusions from

the polygraph tests conducted in respect of the author and his co-defendant were unreliable

because they contradicted the totality of the evidence examined in court, which showed that

the author and his co-defendant had committed the act of arson.

4.7

As to the author’s claim that the Supreme Court of the Komi Republic did not provide

him with the right to determine the composition of the court for the retrial, in violation of

article 30 of the Code of Criminal Procedure, the State Party submits that, before the first

trial, the author petitioned for a preliminary hearing, which was held on 10 July 2007. At the

hearing, on the basis of relevant requests by the author and his co-defendant, the presiding

judge ruled that the trial would be conducted by a panel of three judges. The State Party notes

that, following the quashing of the acquittal judgment on 30 October 2008 by the Supreme

Court of the Russian Federation, the criminal case was remitted for a new examination to the

same first instance court, and there were no legal grounds for holding a new preliminary

hearing and deciding on the composition of the court again. The State Party also notes that

the author’s arguments as to the composition of the court for the retrial were examined by

the cassation court and found to be unsubstantiated.

4.8

With regard to the author’s claim that the same forensic experts and witnesses were

recorded as having participated at the same time in different investigative activities in

different locations, the State Party submits that these allegations were examined by both the

trial court and the cassation court. The courts determined that these forensic specialists and

witnesses, as identified by the author, were involved in different investigative actions carried

out at different times by different investigators, and thus the investigative actions were in

compliance with the rules of criminal procedure and evidence.

4.9

As regards the author’s claims that the courts allowed the prosecution to introduce

evidence that had been obtained unlawfully or lacked credibility, such as wiretappings of the

author’s phone calls from detention facilities and contradicting testimonies of witnesses, the

State Party notes that the trial court recognized the wiretappings mentioned by the author and

the testimonies given by witnesses during the preliminary investigation as admissible

evidence, as they had been obtained in accordance with the requirements of the Code of

Criminal Procedure. The court had no doubts about the credibility of the witnesses’ testimony,

since their testimony was confirmed by the totality of the evidence examined in court and

cited in the judgment. The State Party also notes that the trial court’s findings were confirmed

by the cassation court.

4.10

The State Party submits that, on 8 November 2007, the Supreme Court of the Komi

Republic found that the actions of the case investigator barring the author’s two lawyers from

the case were unlawful and reinstated them in the case. In addition, during the retrial, the

4 The State Party refers to three decisions of the Presidium of the Supreme Court of the Russian

Federation denying the author’s appeals for a supervisory review, dated 17 June 2015, 5 October

2015 and 28 December 2016.

CCPR/C/144/D/3083/2017

GE.25-13043

5

court ensured the participation of both lawyers. The State Party notes that, in its cassation

ruling of 26 October 2009, the Criminal Division of the Supreme Court of the Russian

Federation held that, during the preliminary investigation, the right of the author to defence

had not been violated because, even in the absence of the two barred lawyers, the author had

been provided with an ex officio lawyer.

4.11

As regards the author’s claim that his confession during the pretrial investigation was

given under duress, the State Party submits that, after carefully examining all documents

received from the places of detention where the author had been held during the pretrial

investigation, including medical and video records, the trial court came to the conclusion that

no physical or mental pressure had been exerted on him by law enforcement officers that

would have forced him to give a false confession. The State Party notes that the findings of

the trial court were later confirmed by the cassation court.

Author’s additional claims

5.1

On 15 December 2018, the author submitted additional claims under article 14 (1),

(3) (b) and (5) of the Covenant.

5.2

The author submits that, on 26 October 2009, prior to the cassation hearing before the

Criminal Division of the Supreme Court of the Russian Federation, his co-defendant’s lawyer

submitted an additional cassation appeal, which was directly related to the rights and interests

of the author but contained legal arguments that were different from those made by the author

in his own cassation appeal. However, the author was not provided with a copy of this appeal

or informed that he had the right to submit comments on his co-defendant’s appeal. The

author submits that domestic law requires the courts to ensure that all parties are informed

about any motions or appeals submitted and to provide defendants with an opportunity to

react to those submissions. According to the author, he learned about the additional appeal

on 2 November 2011, that is, after the cassation court had already rendered its decision, when

a copy of the appeal was sent to him in prison without any further explanation.

5.3

On 15 May 2018, the author submitted an appeal for a supervisory review to the

Presidium of the Supreme Court of the Russian Federation, requesting that it quash the

decision of the cassation court dated 26 October 2009 because he had not been provided with

an opportunity to react to his co-defendant’s additional cassation appeal. On 14 June 2018, a

judge of the Supreme Court dismissed the author’s appeal, citing the author’s participation

by video link during the cassation hearing and the similarity of the arguments contained in

his co-defendant’s additional appeal with other arguments made by the author and his

co-defendant during the proceedings.

5.4

On 18 July 2018, the author submitted another appeal for a supervisory review that

was also dismissed by a deputy chairperson of the Supreme Court of the Russian Federation

on 7 August 2018.

5.5

The author claims that, in view of the above, the State Party has violated his rights:

(a) to a fair hearing by a competent, independent and impartial tribunal established by law

(art. 14 (1)); (b) to have adequate time and facilities for the preparation of his defence

(art. 14 (3) (b)); and (c) to have his conviction and sentence reviewed by a higher tribunal

according to law (art. 14 (5)).

Author’s comments on the State Party’s observations on admissibility and the merits

6.1

In a letter dated 19 April 2019, the author submitted his comments on the State Party’s

observations on the admissibility and merits of his original communication. With regard to

the State Party’s argument that the delay in the submission of his communication constitutes

an abuse of the right of submission, the author notes that, under the Optional Protocol, there

is no time limit to submit complaints to the Committee, and a delay in submission will not

automatically constitute an abuse of the right of submission. The author notes that, before

submitting his communication to the Committee, he submitted several complaints to the

European Court of Human Rights, three of which were communicated to the State Party in

CCPR/C/144/D/3083/2017

6

GE.25-13043

2018,5 while others were found to be inadmissible. According to the author, after the verdict

against him had entered into force, he also submitted numerous appeals to higher courts and

the prosecutor’s office. The author argues that he should not bear the negative consequence

of providing the authorities with additional opportunities to remedy the violations committed

at the national level.

6.2

The author rejects the State Party’s argument that he has not exhausted domestic

remedies in respect of his claims under article 14 (3) (d) and (g) of the Covenant. The author

notes that the ruling of the cassation court dated 26 October 2009 states that the defence

argued that the author’s confession had been obtained under duress and that his two lawyers

had been unlawfully barred from the case by the investigator. The author notes that the

Committee does not require reference to specific articles when provisions of the Covenant

are invoked in domestic proceedings.

6.3

As regards the merits of the claims, the author notes that the State Party does not refute

that not all instructions of the cassation court were followed by the first instance court during

the retrial. He submits that, in such circumstances, it cannot be said that the trial court took

all measures provided by law for a comprehensive and objective examination of the case and

provided the necessary conditions in which the parties could exercise their procedural rights

and obligations. The author reiterates his claims with respect to the violation of his rights

under article 14 (1) and (3) (d) and (g) of the Covenant.

State Party’s additional observations

7.1

By note verbale dated 15 December 2020, the State Party submitted its additional

observations on the admissibility and merits of the communication. The State Party notes that

the author’s comments contain the same arguments as his original communication. It

reiterates that it considers the delay of seven years and four months in the submission of the

communication by the author to be an abuse of the right of submission under the Committee’s

rules of procedure. The State Party submits that the author’s complaints to the European

Court of Human Rights that are mentioned in his comments do not contain any claims related

to his communication to the Committee. Specifically, application No. 5264/10 concerns

alleged cruel treatment that took place in 2010–2013, that is, after the author had been

sentenced in 2009. Application No. 11402/17 concerns conditions of detention and the use

of handcuffs during detention. Lastly, application No. 82352/17 concerns his detention in

solitary confinement. The State Party notes that the author has not shown that any other

complaints to the European Court of Human Rights, including those that were found

inadmissible, concern the same facts and the same claims as those raised by him in his

communication to the Committee.

7.2

On the issue of the alleged violation of the author’s right to legal assistance, the State

Party submits that, on 8 November 2007, the Supreme Court of the Komi Republic had

already provided redress by finding the actions of the case investigator unlawful and had

reinstated both lawyers as the author’s defence counsel in the case. Furthermore, the claim

under article 14 (3) (d) of the Covenant should be declared inadmissible for being

incompatible with the provisions of the Covenant. According to the State Party, the author’s

right to legal assistance was never violated because, after his two lawyers had been barred

from continuing to represent him, he was provided with a new lawyer who assisted him

throughout all investigative actions.

7.3

With regard to the author’s claim under article 14 (3) (g) of the Covenant, the State

Party reiterates that the domestic courts concluded that no physical or mental pressure had

been exerted on the author. It notes that the courts examined the video and audio recordings

of the author’s interrogations and noted that his testimonies were calm and voluntary. The

State Party also notes that, in his October 2016 appeal for a supervisory review to the

Supreme Court of the Russian Federation, the author did not contest his conviction or the

evidence admitted by the trial court. Instead, the author petitioned for a change of the sentence

without referring to procedural violations during the pretrial investigation.

5 Application No. 82352/17 was communicated on 22 January 2018, application No. 11402/17 on

11 January 2018 and application No. 5264/10 on 5 September 2018.

CCPR/C/144/D/3083/2017

GE.25-13043

7

7.4

As to the author’s additional claims, the State Party submits that the Supreme Court

of the Russian Federation, in single-judge decisions, twice dismissed the author’s appeals for

a supervisory review, for lack of merit, in relation to the additional appeal submitted by the

author’s co-defendant before the cassation hearing.

Additional comments from the author

8.1

In a letter dated 21 April 2021, the author again rejects the State Party’s submission

that he never raised his claims before the domestic courts. He submits that he raised all his

claims before the domestic courts, including during the first trial when he was acquitted of

all charges, and that, in its decision of acquittal dated 26 June 2008, the Supreme Court of

the Komi Republic mentioned the violations raised by him. According to the author, the State

Party bases its argument that he has not raised his claims in the domestic courts on the

decision of the Supreme Court of the Komi Republic dated 17 June 2009. However, the

author notes that, in the new decision, it is mentioned that he reiterated his testimony from

the first trial, including the claims raised in the present communication. The author notes that

the Supreme Court of the Komi Republic, in its decision dated 17 June 2009, ignored

numerous arguments put forward by the author and his lawyers and did not properly reflect

his claims in its final decision. The author also notes that the claims contained in his

communication were raised by him and his co-defendant in their appeals for supervisory

review.

8.2

In a letter dated 7 September 2021, the author reiterates his argument that there was

no delay in the submission of his communication to the Committee because, in 2010, he

submitted several complaints to the European Court of Human Rights and waited for the

outcome of those complaints before engaging with the Committee. He provides copies of

letters from the European Court of Human Rights confirming receipt of two complaints.

Issues and proceedings before the Committee

Consideration of admissibility

9.1

Before considering any claim contained in a communication, the Committee must

decide, in accordance with rule 97 of its rules of procedure, whether the communication is

admissible under the Optional Protocol.

9.2

The Committee has ascertained, as required under article 5 (2) (a) of the Optional Protocol,

that the same matter is not being examined under another procedure of international investigation

or settlement.

9.3

The Committee takes note of the State Party’s position that, owing to a delay in the

submission of the communication, the Committee should consider the author’s claims

inadmissible as constituting an abuse of the right of submission under article 3 of the Optional

Protocol. The Committee notes that there are no fixed time limits for the submission of

communications under the Optional Protocol and that mere delay in bringing a

communication before the Committee does not in itself involve an abuse of the right of

submission. However, in certain circumstances, the Committee expects a reasonable

explanation justifying a delay.6 In addition, according to rule 99 (c) of the Committee’s rules

of procedure, a communication may constitute an abuse of the right of submission when it is

submitted five years after the exhaustion of domestic remedies by the author of the

communication, or, where applicable, three years from the conclusion of another procedure

of international investigation or settlement, unless there are reasons justifying the delay,

taking into account all the circumstances of the communication.

9.4

In the present case, the communication was submitted to the Committee about seven years

and four months after the author’s sentence had entered into force pursuant to the decision of the

Criminal Division of the Supreme Court of the Russian Federation on 26 October 2009. The

Committee takes note of the author’s argument that he submitted several complaints to the

European Court of Human Rights and waited for the outcome of those complaints before

6 See, for example, M.R. v. Russian Federation (CCPR/C/129/D/2427/2014), para. 8.5; and D.S. v.

Russian Federation (CCPR/C/120/D/2705/2015), para. 6.4.

CCPR/C/144/D/3083/2017

8

GE.25-13043

submitting his communication to the Committee. The Committee also notes the author’s

submission that his three complaints were communicated to the State Party in 2018, while others

were found inadmissible. However, the Committee observes that none of the three complaints

referred to by the author concern the same facts and the same claims as those contained in his

communication. In this regard, the Committee takes note of the State Party’s submission that:

(a) application No. 5264/10 concerns allegations of cruel treatment against the author relating to

the period 2010–2013, that is, after the author had been sentenced in 2009; (b) application

No. 11402/17 concerns the conditions of the author’s detention and the use of handcuffs during

detention; and (c) application No. 82352/17 concerns the author’s detention in a solitary

confinement. The Committee notes that the author has not provided information about any other

complaints submitted to another procedure of international investigation or settlement, including

those that were found inadmissible, that concern the same facts and claims as are raised in the

present communication.

9.5

The Committee also notes the author’s assertion that there were several further complaints

to the Prosecutor’s Office of the Komi Republic and to the Office of the Prosecutor General of the

Russian Federation concerning his case between 2011 and 2016. The Committee considers,

however, that these complaints constitute extraordinary review proceedings launched long after

the judgment against the author became final.7

9.6

Similarly, the Committee notes that the author has not provided any reasons justifying the

delay in submitting his additional claims, as received on 15 December 2018.

9.7

The Committee thus considers that the author has failed to provide an explanation for the

delay in submitting his communication. In the absence of any other information or explanation of

pertinence on file, the Committee considers the delay to be unreasonable and excessive enough to

amount to an abuse of the right of submission, which renders the communication inadmissible

under article 3 of the Optional Protocol and rule 99 (c) of the Committee’s rules of procedure.

10.

The Committee therefore decides:

(a)

That the communication is inadmissible under article 3 of the Optional Protocol;

(b)

That the present decision shall be communicated to the State Party and to the

author.

7 See, for example, Dorofeev v. Russian Federation (CCPR/C/111/D/2041/2011), para. 9.6; and

Salikhov v. Russian Federation (CCPR/C/133/D/2759/2016), para. 9.3.