PART 2: How to Bring a Case to the Court This case dealt with the forced disappearance of a journalist who raised awareness about the lack of freedom of speech in Ukraine. The Committee of Ministers required the respondent State to amend their laws in order to guarantee the independence of investigative bodies.309 A very special general measure is the pilot judgment procedure. The Court developed this type of procedure in order to deal with large groups of identical cases that stem from the same structural problem. If the Court receives a significant number of applications deriving from the same root cause, it can select one or more cases for decision while putting on hold the rest of the similar cases. In this decision, i.e. the pilot judgment, the Court tries to find a solution that extends beyond the particular facts of the single case. Usually a pilot judgment contains significant changes in national legislation. Such a pilot judgment aims at supporting national authorities in eliminating the structural problems and in remedying human rights violations. The Court, for instance, applied the pilot judgment procedure in the case of Torreggiani and Others v. Italy,310 which addressed the systemic dysfunction of the Italian prison system. Several hundred applications against Italy were pending before the Court alleging inhuman prison conditions because detainees only had 3 square meters of personal space in their prison cell. In its judgment, the Court asked the national authorities to put in place within one year, preventive and compensatory remedies that are able to redress the overcrowding in Italian prisons.311 General measures are not claimed by the applicant, but are raised ex officio by the Court or the Committee of Ministers. 2.2 Admissibility 2.2.1 Introduction Before the Court considers an application on the merits, the applicant must satisfy a number of admissibility criteria. The Court’s standing and admissibility rules are contained in Articles 34 and 35 of the Convention. These rules constitute a de facto filtering mechanism by means of which the Court removes a large number of cases 309 Gongadze v. Ukraine, no. 34056/02, Committee of Ministers, ResDH (2008)35, 5 June 2008. 310 Torreggiani and Others v. Italy, nos. 43517/09, 46882/09, 55400/09, 57875/09, 61535/09, 35315/10 and 37818/10, 8 January 2013. 311 Ibid., § 99. Further reading on the pilot judgment proceudre: Philip Leach, Helen Hardman and Svetlana Stephenson, “Can the European Court’s Pilot Judgment Procedure Help Resolve Systemic Human Rights Violations? Burdov and the Failure to Implement Domestic Court Decisions in Russia”, in Human Rights Law Review, vol. 10, 2010, pp. 346–359; Antoine Buyse, “The Pilot Judgment Procedure at the European Court of Human Rights: Possibilities and Challenges”, in The Greek Law Journal, vol. 57, 2009, pp. 1890–1902; Markus Fyrnys, “Expanding Competences by Judicial Lawmaking: The Pilot Judgment Procedure of the European Court of Human Rights”, in German Law Journal, vol. 12, 2011, pp. 1231–1259. 103