In the case of Kreyndlin and Others v. Russia the Court held that there had been a violation of the prohibition on inhuman or degrading treatment taken in conjunction with the prohibition of discrimination.

The case concerned a violent attack on Greenpeace workers in Krasnodar Region, which had potentially been prompted by their connection to Greenpeace or by the assumption they were foreign agents, and the subsequent investigation. The Court found that the investigation had been inadequate and incapable of deterring similar incidents, in particular as a full investigation had only been opened four years later, and it had failed to examine the potential hate motive behind the attack. The State had failed to comply with its obligation to furnish the necessary facilities for the examination of a case.

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