THIRD SECTION
CASE OF ILIEV v. BULGARIA
(Application no. 32908/21)
JUDGMENT
STRASBOURG
22 January 2026
This judgment is final but it may be subject to editorial revision.
In the case of Iliev 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 18 December 2025,
Delivers the following judgment, which was adopted on that date:
1. The case originated in an application against Bulgaria lodged with the Court under Article 34 of the Convention for the Protection of Human Rights and Fundamental Freedoms (“the Convention”) on 18 June 2021.
2. The applicant was represented by Mr Y. Panov, a lawyer practising in Veliko Tarnovo.
3. The Bulgarian Government (“the Government”) were given notice of the application.
THE FACTS
4. The applicant’s details and information relevant to the application are set out in the appended table.
5. The applicant complained of the inadequate conditions of his detention.
THE LAW
6. The applicant complained under Article 3 of the Convention that the conditions of his detention were inadequate.
7. The Court notes that the applicant was kept in detention in poor conditions. The details of the applicant’s detention are indicated in the appended table. The Court refers to the principles established in its case‑law regarding inadequate conditions of detention (see, for instance, Muršić v. Croatia [GC], no. 7334/13, §§ 96‑101, ECHR 2016). It reiterates in particular that a serious lack of space in a prison cell weighs heavily as a factor to be taken into account for the purpose of establishing whether the detention conditions described are “degrading” from the point of view of Article 3 and may disclose a violation, both alone or taken together with other shortcomings (see Muršić, cited above, §§ 122‑41, and Ananyev and Others v. Russia, nos. 42525/07 and 60800/08, §§ 149‑59, 10 January 2012).
8. In the leading case of Neshkov and Others v. Bulgaria, nos. 36925/10 and 5 others, 27 January 2015, the Court already found a violation in respect of issues similar to those in the present case.
9. 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. Having regard to its case-law on the subject, the Court considers that in the instant case the applicant’s conditions of detention were inadequate.
10. These complaints are therefore admissible and disclose a breach of Article 3 of the Convention.
11. Regard being had to the documents in its possession and to its case‑law (see, in particular, Muršić, cited above, § 181), the Court considers it reasonable to award the sums indicated in the appended table.
FOR THESE REASONS, THE COURT, UNANIMOUSLY,
(a) that the respondent State is to pay the applicant, within three months, the amounts indicated in the appended table, to be converted into the currency of the respondent State at the rate applicable at the date of settlement;
(b) that from the expiry of the above-mentioned three months until settlement simple interest shall be payable on the above amounts at a rate equal to the marginal lending rate of the European Central Bank during the default period plus three percentage points.
Done in English, and notified in writing on 22 January 2026, pursuant to Rule 77 §§ 2 and 3 of the Rules of Court.
Viktoriya Maradudina Canòlic Mingorance Cairat
Acting Deputy Registrar President
APPENDIX
Application raising complaints under Article 3 of the Convention
(inadequate conditions of detention)
Date of introduction | Applicant’s name Year of birth
| Facility Start and end date Duration | Specific grievances | Domestic award (in euros) | Amount awarded for non-pecuniary damage per applicant (in euros)[1] | Amount awarded for costs and expenses per application (in euros)[2] |
32908/21 18/06/2021 | Krasimir Ivanov ILIEV 1973
| Lovech Prison 05/12/2016 to 30/04/2017 4 month(s) and 26 day(s) | infestation of cell with insects/rodents, lack of fresh air, lack of or inadequate hygienic facilities, lack of or insufficient natural light, lack of or poor quality of bedding and bed linen, lack of privacy for toilet, lack of requisite medical assistance, mouldy or dirty cell | 288
(BGN 500 plus interest BGN 63) | 2,200 | 250 |
[1] Plus any tax that may be chargeable to the applicant.
[2] Plus any tax that may be chargeable to the applicant.