Comments
On May 12, 2014, the Grand Chamber of the European Court of Human Rights (the Court) in Cyprus v. Turkey ordered Turkey to pay Cyprus €90,000,000 (approximately $123,400,000) in relation to breaches of the European Convention on Human Rights (ECHR). According to the press release, Turkey committed such violations in the context of “military operations it had conducted in northern Cyprus in July and August 1974, the continuing division of the territory of Cyprus and the activities of the ‘Turkish Republic of Northern Cyprus.’” Although the Court identified those breaches in its judgment of May 10, 2001, the Court held that Cyprus’s claim for just satisfaction was not time-barred in light of the fact that “no time-limits had been fixed for the parties to submit their just satisfaction claims.” In relation to the applicability of Article 41 of the ECHR (just satisfaction) to an inter-State claim, the Court held that “the overall logic of Article 41 of the Convention was not substantially different from the logic of reparations in public international law” and thus just satisfaction could be awarded “for the benefit of individual victims.” Accordingly, the awarded amounts were “to be distributed by the Cypriot Government to the individual victims under the supervision of the Committee of Ministers