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 [3] 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 [4] 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 [5], 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.”