On October 13, 2020, the Third Section of the European Court of Human Rights (ECtHR) issued its judgment in Zakharov and Varzhabetyan v. Russia [3], a case implicating Articles 3 (degrading treatment and effective investigation) and 11 (freedom of peaceful assembly). The applicants in the case were part of a political rally at Bolotnaya Square in Russia on May 6, 2012, which led to a skirmish between the police and the protestors, which eventually was dispersed by the police. According to a Case Information Note [4] from the Court, the applicants had alleged that they were hit on the head by the police during the dispersal of the rally and were unable to persuade the local authorities to launch a criminal investigation into the alleged treatment. The ECtHR held unanimously that there was a violation of Article 3 because of the national authorities' failure to initiate an investigation into the matter. The Court went on to address the applicants' complaints relating to their treatment by the police and found that the "use of force against [the applicants] had . . . not been strictly necessary . . . and thus had diminished [the applicants'] dignity" in violation of Article 3's prohibition on inhumane and degrading treatment. Finally, the Court held that the state failed to justify the police's use of force against the applicants and that therefore Article 11 had been violated. The Court noted that not only was the use of force unnecessary, but that "it could have had a chilling effect and discouraged the applicants and others from taking part in similar public gatherings." It is unclear whether the parties will seek a referral of this case to the Grand Chamber.