Article 3 of the European Convention on Human Rights: A Practitioner’s Handbook if any, is too remote and uncertain. The Court concludes that the second applicant’s claims for pecuniary damages are unjustified and must be rejected.282 The Court applies the causal link requirement strictly. Claims for pecuniary damage often fail before the Court. An applicant is therefore advised to clearly document and explain that the loss of earnings or a medical bill etc. were caused by the human rights violation. Normally, the Court’s award reflects the full amount of the damage. However, if the actual damage cannot be precisely calculated, the Court will make an estimate based on the facts at its disposal. In doing so, it is also possible that the Court find reasons in equity to award less than the full amount of the loss.283 ii) Non-pecuniary Damage When the Court finds an Article 3 violation it typically grants non-pecuniary damage that provides financial compensation for non-material harm such as mental or physical suffering. In the case of Dybeku v. Albania,284 for instance, the Court reasoned: As regards non-pecuniary damage, the Court observes that it has found that the applicant’s rights under Article 3 of the Convention have been violated. It considers that the applicant suffered damage of a non-pecuniary nature, as a result of his detention in inhuman and degrading conditions, inappropriate to his state of health […], which is not sufficiently redressed by the finding of a violation of his rights under the Convention.285 Likewise, in the case of Kalashnikov v. Russia286 the Court stated that The Court considers that the length of the applicant’s detention on remand in such prison conditions, as well as the length of the criminal proceedings, must have caused him feelings of frustration, uncertainty and anxiety which cannot be compensated solely by the finding of a violation.287 In terms of the amount the Court grants, it will make an assessment on an equitable basis and might not award the full loss suffered. Thus, applicants should be aware that even where his or her claim is based on supporting documents, the Court might award a lower amount than the sum claimed. 282 Ibid., § 940. 283 See Practice Directions, Just satisfaction claims, available online: www.echr.coe.int/Documents/PD_satisfaction_claims_ENG.pdf 284 Dybeku v. Albania, no. 41153/06, 18 December 2007. 285 Ibid., §§ 67–68. 286 Kalashnikov v. Russia, no. 47095/99, 15 July 2002. 287 Ibid., § 142. See also Zenkov v. Russia, no. 37858/08, 30 April 2014, § 67. 100