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United Kingdom

Bradshaw v UK: ECtHR finds no Article 3 of Protocol 1 investigative duty over alleged Russian interference; UK response within wide margin; concurring opinion seeks clearer ECHR standards

Published on: 23 July 2025

Published by a LexisNexis Public Law expert
Legal News
Table of contents
  • Background
  • Judgment
  • Reasons for the judgment
  • Comment
  • Carl Gardner, professional support lawyer in the Public Law team at LexisNexis
Article summary

Bradshaw and others v United Kingdom, Application no. 15653/22

Background

In 2019 and 2020, the House of Commons Digital, Culture, Media and Sport Committee, alongside Parliament’s Intelligence and Security Committee, issued reports addressing Russian meddling in the 2014 Scottish independence vote, the 2016 EU membership referendum, and the 2019 UK general election. While still serving as MPs at that time, the applicants were unsuccessful in formally seeking judicial review of the government’s refusal to order an independent inquiry, contending, among other grounds, that this contravened the investigative duty implicit in Article 3 of Protocol 1.

Judgment

The ECtHR concluded, unanimously, that Article 3 of Protocol 1 had not been breached whatsoever.

Reasons for the judgment

The ECtHR considered there to be no settled consensus about precisely what...

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