Ramirez Sanchez v. France

European Court of Human Rights
4 July 2006


The applicant, Mr. Sanchez, was implicated in terrorist attacks, convicted for three murders and sentenced to life imprisonment. He was placed in solitary confinement where he stayed for 8 years and two months. During this time his physical and mental health satisfactory. The reasons stated in the decisions prolonging his solitary confinement were his dangerousness, the need to maintain order and security in the prison and the risk of his absconding.


Mr. Sanchez complained that his prolonged solitary confinement violated Article 3 of the Convention. 

Court's ruling

The Court emphasized that solitary confinement, even in cases entailing only relative isolation, could not be imposed on a prisoner indefinitely. In Court’s view in order to avoid any risk of arbitrariness, substantive reasons had to be given when a protracted period of solitary confinement was extended and such measures, which constituted a form of “imprisonment within the prison”, were to be resorted to only exceptionally and after every precaution had been taken. 

In the particular case the Court found that Mr. Sanchez was considered to be the most dangerous terrorist in the world in 1970ties, thus it agreed with the national authorities that a strict prison regime was necessary. It was also satisfied with the fact that Mr. Sanchez was regularly seen by a doctor and psychiatrist who did not advise against the solitary confinement. He was also regularly visited by a priest and one of his 58 lawyers. There were also no restrictions to family visits although such option was never used. 

Therefore the Court considered his isolation partial and relative. The Court also did not found the government’s fears that he may try to seek to proselytise other prisoners or to prepare an escape unreasonable. Therefore, while emphasizing that prolonged solitary confinement should be used only in very exceptional situations, in the particular case the Court found no violation of Mr. Sanchez’s rights under Article 3.

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Last updated 18/11/2023