On January 31, 2019, in the just satisfaction case of Georgia v. Russia (I), the Grand Chamber of the European Court of Human Rights ordered Russia to pay compensation to over 1,500 Georgian nationals for violations of Article 4 of Protocol No. 4 (collective expulsion), Article 5 § 1 (unlawful deprivation of liberty), and Article 3 (inhuman and degrading conditions of detention) of the European Convention on Human Rights. The case concerned a judgment on the merits from 2014 where the Court held that the Russian government implemented a coordinated policy in 2006 of arresting, detaining, and expelling Georgian nationals, which amounted to an administrative practice for purposes of the Convention. As noted in the press release, this was the first time since Cyprus v. Turkey in 2014 that the Court had ruled on the question of just satisfaction in an inter-state case, and it referred “to the principle of public international law relating to a State’s obligation to make reparation for violation of a treaty obligation, and to the case-law of the International Court of Justice, before concluding that Article 41 of the Convention did, as such, apply to inter-State cases.”