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Art 34 • Ill-treatment and death of applicants� relative in police custody • Locus standi of cousin not automatically recognised unlike that of victim�s mother and siblings • Absence of information demonstrating a legitimate interest for cousin�s legal standing before the Court • Acting as victim�s legal heir in domestic proceedings insufficient in itself
Art 2 and Art 3 (procedural and substantive) • Ineffective investigation into ill-treatment and death, focused solely on official suicide version • Serious breaches of Art 2 and 3 procedural requirements • State�s failure to discharge burden of proof by providing satisfactory explanation for death and injuries
This judgment will become final in the circumstances set out in Article 44 � 2 of the Convention. It may be subject to editorial revision.
The European Court of Human Rights (Fourth Section), sitting as a Chamber composed of:
the application (no. 2265/12) against the Republic of Armenia lodged with the Court under Article 34 of the Convention for the Protection of Human Rights and Fundamental Freedoms (�the Convention�) by four Armenian nationals, Ms Anahit Vardanyan, Mr Vardan Khalafyan, Mr Hmayak Khalafyan and Ms Ani Khalafyan (�the applicants�), on 14 December 2011;
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