Article 3 of the European Convention on Human Rights: A Practitioner’s Handbook 2.2.2 Victim Status (Article 34) a) Introduction Article 34 governs the question of standing before the Court. It states that the Court may receive applications from any person, non-governmental organisation or group of individuals claiming to be the victim of a violation by one of the High Contracting Parties of the rights set forth in this Convention or the protocols thereto. The term “person” covers not only natural persons but also legal persons, such as trade unions,323 political parties,324 companies325 or other associations.326 However, governmental organisations or State-owned companies cannot bring an application to the Court against their own State under the theory that a Contracting Party cannot complain against itself to the Court.327 The Court distinguishes between three different types of victims: direct victims, potential victims and indirect victims. b) Direct Victim Most applicants before the Court are direct victims who have been personally affected by a measure, act or omission of a Contracting Party. Hence, a direct victim is for instance a person who has been tortured or has been held in detention. A person may lose his or her victim status if the violation is appropriately remedied by the Contracting Party.328 The term “victim” is interpreted autonomously and is not dependent on notions of “standing” or “interest” under domestic law.329 It denotes a person who is directly affected330 by a governmental act or omission or, in other words, a person who can show “a sufficiently direct link between the applicant and the harm which they consider they have sustained on account of the alleged violation.” 331 323 Wilson, National Union of Journalists and Others v. the United Kingdom, nos. 30668/96, 30671/96 and 30678/96, 2 July 2002. 324 Refah Partisi (the Welfare Party) and Others v. Turkey [GC], nos. 41340/98, 41342/98, 41343/98 and 41344/98, 13 February 2003. 325 Bosphorus Hava Yolları Turizm ve Ticaret Anonim Şirketi v. Ireland [GC], no. 45036/98, 30 June 2005. 326 The Holy Monasteries v. Greece, nos. 13092/87 and 13984/88, 9 December 1994. 327 RENFE v. Spain, no. 35216/97, Commission decision, 8 September 1997. 328 See Eckle v. Germany, no. 8130/78, 15 July 1982, § 66. 329 Gorraiz Lizarraga and Others v. Spain, no. 62543/00, 27 April 2004, § 35, and Sanles Sanles v. Spain (dec.), no. 48335/99, 26 October 2000. 330 Amuur v. France, no. 19776/92, 25 June 1996, § 36. 331 Ibid. See also Comité des médecins à diplômes étrangers v. France and Others v. France (dec.), nos. 39527/98 and 39531/98, 30 March 1999. 106