Armenian Officer's Family Secures Final European Court Ruling Holding Azerbaijan Responsible for His Death

A European court ruling holding Azerbaijan responsible for the torture and beheading of an Armenian military officer during the April 2016 war in Nagorno-Karabakh has become final, nearly a decade after his death.
The European Court of Human Rights announced November 2 that a five-judge panel had rejected a request to review its judgment in the case of Hayk Toroyan, a 30-year-old Armenian major killed during fighting between Armenian and Azerbaijani forces.
Armenian lawyers said Azerbaijan had sought the review. The rejection makes the court’s June 18 ruling final and binding.
It is the first judgment issued by the Strasbourg-based court concerning the four-day war in April 2016. Another 21 applications related to the fighting remain under examination.
Toroyan was serving at a military unit in Mataghis, in northern Nagorno-Karabakh, when Azerbaijani forces launched an offensive in April 2016. He and another Armenian serviceman, Hrant Gharibyan, were transporting ammunition to a command post in Talish when they came under attack, according to CivilNet.
Toroyan’s body was later recovered without its head and hands. Photographs of his severed head circulated online, and some of his remains were never returned to his family.
In its June judgment, the European Court found that Azerbaijani soldiers had tortured Toroyan before killing him by decapitation. Judges rejected Azerbaijan’s suggestion that Armenian forces could have staged the incident, finding that Baku had offered no evidence to support its account.

The court also ruled that Azerbaijani authorities had failed to carry out an effective investigation into his death.
Judges found violations of the European Convention on Human Rights, including the right to life and the prohibition of torture. They also determined that the treatment of Toroyan’s remains and the suffering endured by his relatives amounted to a separate violation of the convention.
Azerbaijan was ordered to pay his family 90,000 euros, approximately $103,000, in compensation. His parents were awarded 60,000 euros and his sister 30,000 euros. The court also ordered Azerbaijan to pay 14,210 euros in legal costs.
The case was brought by Toroyan’s parents and sister, represented by Armenian lawyer Siranush Sahakyan. Armenia participated in the proceedings as a third party.
Sahakyan has said that 23 cases involving alleged crimes committed during the April 2016 fighting were submitted to the European court against Azerbaijan, including three involving beheadings.
Speaking to Azatutyun after the June ruling, she expressed frustration that it had taken nearly 10 years for the court to deliver its first judgment on the war.
The decision could also affect other cases awaiting rulings.
Liparit Drmeyan, the former head of Armenia’s Office of the Representative on International Legal Matters, said the judgment would provide an important legal foundation for similar complaints.
He also questioned Azerbaijan’s decision to seek a review after its leadership had publicly challenged the authority of the European court.
Baku rejected the original ruling in June. Chingiz Asgarov, Azerbaijan’s representative before the court, accused judges of relying on insufficient evidence and favoring materials submitted by Armenia.
The dispute comes amid worsening relations between Azerbaijan and the Council of Europe, the human rights organization that oversees the court.
In January 2024, the Parliamentary Assembly of the Council of Europe refused to ratify the credentials of Azerbaijan’s delegation, citing concerns over the country’s compliance with its membership obligations.
Azerbaijani President Ilham Aliyev said in April 2025 that his country no longer considered the European court’s decisions valid because its delegation had been excluded from participating in the election of judges.
According to the Council of Europe’s Committee of Ministers, Azerbaijan stopped cooperating with the body on the implementation of court judgments after March 18, 2025. Aliyev later said in July 2026 that Baku was seriously considering leaving the organization altogether.

Despite those statements, Azerbaijan sought to challenge the Toroyan ruling through the court’s established appeals procedure.
The rejection ends the judicial proceedings in Toroyan’s case, although Azerbaijan’s compliance with the judgment remains subject to supervision by the Council of Europe’s Committee of Ministers.
The ruling also comes as Armenia and Azerbaijan pursue a peace agreement following decades of conflict over Nagorno-Karabakh.
Unlike cases filed by governments against one another, Toroyan’s case was brought directly by his family. Such individual applications could become increasingly important if Armenia and Azerbaijan agree to withdraw interstate legal claims as part of their peace negotiations.
Legal analyst Igor Mirzakhanyan, writing for Strasbourg Observers, has argued that individual cases may offer victims one of the few remaining opportunities to seek accountability through international courts.
For Toroyan’s family, the judgment establishes Azerbaijan’s legal responsibility for his death. For other families whose cases remain unresolved, it is the first ruling from the European court addressing the treatment of Armenian servicemen during the April 2016 war.
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