Sending the complaints to the EGMR (European Court of Human Rights; EGMR, Council of Europe, F-67075 Strasbourg-Cedex, France)

Dmitry Bagrash, JVA Heidering (Heidering Prison), Ernst-Stargardt-Allee 1, 14979 Großbeeren — To the Registrar, European Court of Human Rights, Council of Europe, 1 avenue de l’Europe, 67075 Strasbourg Cedex, France. 13.10.2025. Request for interim measures under Rule 39 of the EGMR’s Rules of Court.

Presentation note: The original request runs to 58 pages with 16 thematic sections (7.1–7.16), each detailing the facts, evidence and relevant EGMR case law with case references. Because of its considerable length and recurring structure, a faithful summary of the key points is given below; the full wording can be viewed through the Drive link below.

1. Parties

Applicant: Dmitry Bagrash, born 09.05.1968, Russian nationality, currently detained at JVA Heidering. Respondent: Federal Republic of Germany. Legal representation: currently none (without defence counsel).

2. Urgency under Rule 39

Core complaint: practical access to justice is effectively blocked; the individual application is obstructed. Brief facts: absent or late § 37 acknowledgments of receipt; access to registry officials denied / delayed, sometimes only available after a hunger strike; failure to forward / returns (“Acceptance refused”); EGMR drafts retained / seized; time-critical religious contacts (Art. 9) blocked.

3. Subject of the request — interim measures sought

1. Unimpeded, confidential, timely access to a registry official (UKB), fax, post and other means of communication with courts, the EGMR and legal representatives, with registration, acknowledgment (§ 37 StPO) and forwarding. 2. Safeguarding religious practice (Art. 9 EMRK): contact and visits by rabbis and the Jewish community, telephone / post, access to religious objects / rituals. 3. Securing effective defence and access to the case file: immediate acceptance of supplements to the grounds of appeal on points of law, complaints concerning violations of the right to be heard (Anhörungsrügen), and complaints; no “putting aside” without formal procedure (formlose Weglegung). 4. Provision of necessary working and communication resources in the prison (writing materials, copies / scans, printouts); medical safeguards during a hunger strike. 5. Preservation of the status quo regarding the judgment of 22.07.2024 and the subsequent order of 30.07.2025: refraining from any measure that could further irreversibly worsen legal protection.

4. Political visibility before detention

My political work as chairman of UnKremlin e.V. was internationally visible long before my detention and was obstructed by authorities in Berlin. As early as 24.09.2021 the Russian delegation to the OSZE (OSCE) expressly named UnKremlin e.V. in a statement on “foreign interference” surrounding the Duma election; on 08.04.2022 (OSZE document PC.DEL/526/22) the Russian delegation again cited UnKremlin e.V. On 17.09.2021 — the weekend of the Russian Duma election — Senior Public Prosecutor Raupach personally ordered the immediate seizure of my banner “Putin is a Killer” during a properly notified action opposite the Russian embassy; the subsequent proceedings for alleged insult were discontinued after several months under § 170 StPO. In my view, this dual track (international visibility + local intervention) refutes the interpretation in the judgment of 22.07.2024 that my political activity had been “insignificant”.

5. Legal assessment (extract)

Violations are alleged of Art. 34 EMRK (prohibition on obstructing an individual application), Art. 6 EMRK (access to court, fair-trial guarantees, equality of arms / case-file access), Art. 13 EMRK (effective remedy) and Art. 9 EMRK (freedom of religion). The 16 thematic sections deal in detail, inter alia, with lack of access to justice and registry officials, ignored substantive objections in BGH orders, the subsequent “correction” of the operative part of the judgment of 30.07.2025, ignored submissions to the Senate Department for Justice, obstacles to EGMR access, religious practice (Case 3), the pattern “Deception as a Modus Operandi” (1–6), transfers and withdrawal of writing materials, health risks from hunger strikes as a last resort, and blocked change of counsel and denied case-file access. Each section refers to extensive EGMR case law (including Golder/United Kingdom, Airey/Ireland, Kudła/Poland, Akdivar and others/Turkey, Mamatkulov and Askarov/Turkey, Zubac/Croatia, Campbell and Fell/United Kingdom).

8. Specific requests in their original wording

The applicant requests an interim-measures order under Rule 39 requiring the Federal Republic of Germany to: 1. ensure regular access to registry officials and proper registration / acknowledgment / forwarding of all letters to courts / the EGMR; 2. refrain from any seizure, delay, retaliation (retorsion) or other obstruction of judicial / EGMR correspondence; 3. make writing, copying and communication resources available and guarantee medical safeguards during hunger strikes; 4. fully ensure religious practice; 5. refrain, until the decision on the merits, from any measure worsening the legal position, particularly retroactive “corrections” to the operative part of the judgment.

Place / date: Großbeeren, 13.10.2025. Signature: Dmitry Bagrash