The European Court of Human Rights: Catan and Others v. Moldova and Russia
On October 19, 2012, the Grand Chamber of the European Court of Human Rights (the Court) ruled that policies pursued by de facto authorities in the Transdniestrian region of the Republic of Moldova aimed at suppressing Moldovan-language education violated the right to education of the affected children and their parents. The Court held Russia responsible for these violations by virtue of the continued vital support Russia provides to the de facto authorities. Meanwhile, the Court found Moldova to have complied with residual human rights obligations it retained, despite lacking effective control over Transdniestria. This important judgment develops the jurisprudence of the Court in relation to human rights violations arising from conduct of de facto authorities. However, it does not fully clarify the standards the Court applies in attributing their conduct to third states.