issued by the Registrar of the Court
ECHR 244 (2025)
23.10.2025
Judgments and decisions of 23 October 2025
The European Court of Human Rights has today notified in writing 32 judgments1 and 45 decisions2:
one Chamber judgment is summarised below;
two separate press releases have been issued for two Chamber judgments in the cases of Ayala Flores
v. Italy (application no. 16803/21) and A.J. and L.E. v. Spain (nos. 40312/23 and 40388/23);
two press releases have also been issued for two decisions in the cases of Fillon and Others v. France
(application no. 24326/24) and Otegi Mondragon and Others v. Spain (no. 14186/24);
29 Committee judgments, concerning issues which have already been examined by the Court, and the
The judgment summarised below is available only in English.
Tartamella and Others v. Italy (application nos. 26338/19, 1823/21, and
12868/22)
The applicants, Francesca Tartamella, Barbara Tartamella, Szilvia Koka, and Silvia Santorelli, were born
in 1982, 1980, 1974 and 1985, respectively. Francesca Tartamella and Barbara Tartamella are Italian
nationals; Ms Koka is Hungarian; and Ms Santorelli is Romanian. They live in Perigua (Italy), London,
Costa (Corsica, France) and Savignano (Italy) respectively.
The case concerns the seizure and confiscation of assets belonging to them, the value of which was
deemed to be equivalent to the proceeds from offences committed by their family members. The
measures were based on the finding that, even though the applicants were the formal owners of the
assets, those assets were at the disposal of the offenders.
Relying on Articles 7 (no punishment without law) of the European Convention on Human Rights and
Article 1 of Protocol No. 1 (protection of property) to the European Convention, the applicants
complain that, by seizing and confiscating their assets, the domestic courts had punished them for an
offence committed by others and that the seizure and confiscation had been disproportionate and not
sufficiently foreseeable. Relying on Article 6 § 1 (right to a fair hearing) of the Convention, Ms Koka
also complains that she did not have access to an effective remedy by which to contest the
confiscation of her assets.
No violation of Article 6 § 1 in respect of the third applicant
Violation of Article 1 of Protocol No. 1 in respect of the first two applicants
No violation of Article 1 of Protocol No. 1 in respect of the third and fourth applicants
Just satisfaction: The Court held that the question of the application of Article 41 (just satisfaction) in
relation to application no. 26338/19 was not ready for decision in so far as pecuniary damage was
1
Under Articles 43 and 44 of the Convention, Chamber judgments are not final. During the three-month period following a Chamber
judgment’s delivery, any party may request that the case be referred to the Grand Chamber of the Court. If such a request is made, a panel
of five judges considers whether the case deserves further examination. In that event, the Grand Chamber will hear the case and deliver a
final judgment. If the referral request is refused, the Chamber judgment will become final on that day. Under Article 28 of the Convention,
judgments delivered by a Committee are final.
Once a judgment becomes final, it is transmitted to the Committee of Ministers of the Council of Europe for supervision of its execution.
Further information about the execution process can be found here: www.coe.int/t/dghl/monitoring/execution
2
Inadmissibility and strike-out decisions are final.
