THIRD SECTION

CASE OF RANGELOV AND OTHERS v. BULGARIA

(applications nos. 49395/21 and 14 others – see appended list)

 

 

 

 

 

 

JUDGMENT

 

STRASBOURG

23 October 2025

 

 

 

This judgment is final but it may be subject to editorial revision.

 


In the case of Rangelov and Others v. Bulgaria,

The European Court of Human Rights (Third Section), sitting as a Committee composed of:

 Canòlic Mingorance Cairat, President,
 Diana Kovatcheva,
 Vasilka Sancin, judges,

and Viktoriya Maradudina, Acting Deputy Section Registrar,

Having deliberated in private on 2 October 2025,

Delivers the following judgment, which was adopted on that date:

PROCEDURE

1.  The case originated in applications against Bulgaria 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.

2.  The applicants were represented by Ms V. Radieva, a lawyer practising in Burgas.

3.  The Bulgarian Government (“the Government”) were given notice of the applications.

THE FACTS

4.  The list of applicants and the relevant details of the applications are set out in the appended table.

5.  The applicants complained of their ineligibility, as convicted prisoners, to vote in legislative elections in breach of the prohibition of discrimination.

THE LAW

  1. JOINDER OF THE APPLICATIONS

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

  1. ALLEGED VIOLATION OF ARTICLE 3 OF PROTOCOL No. 1

7.  The applicants complained principally of their ineligibility as convicted prisoners to vote in legislative elections. They relied, expressly or in substance, on Article 3 of Protocol No. 1 to the Convention.

8.  The Court refers to the principles established in its caselaw regarding ineligibility to vote in elections (see, among other authorities, Hirst v. the United Kingdom (no. 2) [GC], no. 74025/01, §§ 56-71, ECHR 2005IX; Scoppola v. Italy (no. 3) [GC], no. 126/05, §§ 81-87, 22 May 2012; and Anchugov and Gladkov v. Russia, nos. 11157/04 and 15162/05, §§ 93100, 4 July 2013). The essence of these principles, reiterated in all of these key cases, is that when disenfranchisement affects a group of people generally, automatically and indiscriminately, solely on the basis that they are serving a prison sentence, irrespective of the length of the sentence and irrespective of the nature or gravity of their offences and their individual circumstances, it is not compatible with Article 3 of Protocol No. 1.

9.  In the leading case of Kulinski and Sabev v. Bulgaria (no. 63849/09, 21 July 2016), the Court already found a violation in respect of issues similar to those in the present case.

10.  Having examined all the material submitted to it, the Court has not found any fact or argument capable of persuading it to reach a different conclusion on the admissibility and merits of these complaints.

11.  These complaints are therefore admissible and disclose a breach of Article 3 of Protocol No. 1.

  1. OTHER ALLEGED VIOLATIONS UNDER WELL-ESTABLISHED CASE-LAW

12.  The applicants also complained under Article 14 of the Convention in respect of the same set of facts. Having regard to the conclusion above under Article 3 of Protocol No. 1, the Court considers that while this complaint is admissible, no separate issue arises under Article 14 of the Convention in the circumstances of the present case (compare Hirst (no. 2), §§ 87 and 89, and Anchugov and Gladkov, § 116, both cited above).

  1. APPLICATION OF ARTICLE 41 OF THE CONVENTION

13.  Regard being had to the documents in its possession and to its caselaw (see, in particular, Tingarov and Others v. Bulgaria, no. 42286/21, 10 October 2023), the Court considers that the finding of a violation constitutes sufficient just satisfaction in the present cases.

FOR THESE REASONS, THE COURT, UNANIMOUSLY,

  1. Decides to join the applications;
  2. Declares the applications admissible;
  3. Holds that the applications disclose a breach of Article 3 of Protocol No. 1 to the Convention concerning the ineligibility of convicted prisoners to vote in legislative elections;
  4. Holds that no separate issue arises under Article 14 of the Convention;
  5. Holds that the finding of a violation constitutes in itself sufficient just satisfaction.

Done in English, and notified in writing on 23 October 2025, pursuant to Rule 77 §§ 2 and 3 of the Rules of Court.

 

 Viktoriya Maradudina Canòlic Mingorance Cairat

 Acting Deputy Registrar President

 

 


APPENDIX

List of applications raising complaints under Article 3 of Protocol No. 1 to the Convention

(ineligibility of convicted prisoners to vote in legislative elections)

No.

Application no.

Date of introduction

Applicant’s name

Year of birth

 

Type of restriction

Election details

  1.    

49395/21

27/09/2021

Tsvetan Georgiev RANGELOV

1961

Impossibility for the applicants, convicted prisoners, to vote in parliamentary elections

National parliamentary elections, 04/04/2021

  1.    

49396/21

27/09/2021

Ivan Nikolaev RIBOV

1979

National parliamentary elections, 04/04/2021

  1.    

49397/21

27/09/2021

Emil Georgiev KOSTADINOV

1966

National parliamentary elections, 04/04/21

  1.    

49398/21

27/09/2021

Asen Hristov ASENOV

1976

National parliamentary election, 04/04/2021

  1.    

49657/21

27/09/2021

Todor Iliev DIMITROV

1970

National parliamentary elections, 04/04/2021

  1.    

49659/21

27/09/2021

Biser Yavorov MILANOV

1978

National parliamentary elections, 04/04/2021

  1.    

49661/21

27/09/2021

Hristo Atanasov ATANASOV

1959

National parliamentary elections, 04/04/2021

  1.    

4598/22

11/01/2022

Ivan Georgiev KALAYDZHIEV

1976

National parliamentary elections, 11/07/2021

  1.    

4605/22

11/01/2022

Encho Kostadinov ENCHEV

1970

National parliamentary elections, 11/07/2021

  1.  

26386/22

13/05/2022

Eduard Dimitrov PAVLOV

1968

National parliamentary elections, 14/11/2021

  1.  

26396/22

13/05/2022

Petar Mitev DEMIREV

1980

National parliamentary elections, 14/11/2021

  1.  

26399/22

13/05/2022

Ivan Stoyanov IVANOV

1965

National parliamentary elections, 14/11/2021

  1.  

30364/23

29/07/2023

Krasimir Tsvetkov KAMENOV

1974

National parliamentary elections, 02/04/2023

  1.  

30366/23

29/07/2023

Ivan Tsvetanov IVANOV

1983

National parliamentary elections, 02/04/2023

  1.  

30368/23

29/07/2023

Yuliyan Lyubomirov ZASHEV

1975

National parliamentary elections, 02/04/2023