This paper examines whether (and if so, on what basis) the events taking place
in Nagorno-Karabakh after the signature of a trilateral ceasefire agreement in
November2020 would fall within the jurisdiction under the European Convention
on Human Rights (ECHR) of Azerbaijan as a territorial State; Armenia as
potentially exercising effective control there; or Russia given the presence of its
peacekeeping mission in the region. It also outlines the future developments
after Russia ceases to be the party to the ECHR. On the example of Nagorno-
Karabakh, the paper demonstrates the limits to the European Court of Human
Rights’ approach to jurisdiction over secessionist entities under the ECHR. In
particular, it highlights the relativity of the requirement of the presence of the
‘boots on the ground’ as the element of the effective control test under a spatial
extra-territorial model of jurisdiction.
