K.A. Etdzaeva

On January 21, 2021, the European Court of Human Rights (ECtHR) delivered the judgment on the interstate complaint “Georgia v. Russia (2)”. The purpose of this article is to examine the views of the ECHR to resolving complex issues of the Russian jurisdiction over South Ossetia, Abkhazia and the “buffer zone” in the context of an international military conflict. This judgment is unique one, since the ECtHR used two models of extraterritorial jurisdiction of the member states developed in its practice. In this regard, the article presents a brief analysis of the essence of each of the models and then the author of the article provides an overview of the ECtHR’s case law on the matter, which was once again reconsidered by the Court in this case. In the final part of the article, the author refers to the key remarks made by nine judges of the ECtHR in their dissenting opinions. The author concludes that this judgment has led to even greater confusion in the ECtHR’s case law on the extraterritorial application of the Convention, which raises serious reputational issues before the Court