video that V. was in a room behind bars, separated from the medic who was outside. In the video, V. shows traces left by the beatings, including huge hematomas which can be clearly seen. However, in its report to the European Court on the implementation of the interim measures indicated in V.’s case, Russia claimed that medics had not documented any injuries. III. Fabricating false evidence of innocence Another common problem is the use of so-called “activists” in penal colonies (prisoners who cooperate with the prison administration). These inmates are often used as alleged eyewitnesses testifying that there was no beating. Since the administrations of penitentiary institutions have full control over the evidence of torture, they use their power to put pressure on witnesses, forcing them to give false statements. IV. Pressure on victims of torture and ill-treatment Bringing retaliatory charges against individuals who report torture to the authorities is a widespread practice. In particular, applicants often face “false accusation” charges, in which their torture report is treated as a false accusation. The Russian NGO Coalition’s Shadow Report covers this issue extensively as well. Convicted prisoners are particularly vulnerable to false accusation charges. Indeed, they are likely to face persistent and serious threats of prosecution under this article to force them to withdraw torture complaints. But in our practice, we have also noted cases of people in the community who reported torture by police and faced charges and trials under Article 306 (false accusation). Being sentenced under Article 306 effectively deprives a person from any further opportunity to have their torture complaint investigated. V. What has been the impact of the European Court’s judgments on the enforcement practice? According to the Russian Criminal Procedure Code, the European Court of Human Rights (ECtHR) judgments are considered “emerging new circumstances” that warrant re-examination of prior decisions of domestic courts which are already in effect (Article 413, part 4 (2) of the Criminal Procedure Court). Below are some observations on how the European Court’s judgments against Russia in cases alleging torture have influenced the possibility of having domestic proceedings reopened in cases where confessions under duress were used as evidence of guilt. In the Mikheyev group of cases, the Court found Russia in violation of Article 3 (prohibition of torture) in 172 cases, and in 27 cases, the Court also found a violation of Article 6 (right to a fair trial) due to the use of confessions extracted under torture as evidence in court. According to a Memorandum prepared by the Department for the Execution of ECtHR Judgments and providing an overview of the current situation with respect to the individual measures in the Mikheyev group of cases (H/Exec(2021)18 – 16 November 2021, H/Exec(2021)18 - Memorandum - Mikheyev v. Russian Federation group of cases (coe.int)), only in one of the 27 cases, was the applicant acquitted after his prior conviction based on statements made under duress was quashed. In another case, the new proceedings were discontinued following the applicant’s death, and in yet another, the case was remitted for re-examination in 2014, but the Russian Federation has not yet provided information on the outcome. In six cases, the new proceedings upheld the original guilty verdicts and sentences. Moreover, in two cases, Abdulkadyrov and Dakhtayev, 35061/04, and Mukayev, 22495/08, the Presidium of the Supreme Court found the applicants’ reports of torture inconsistent and unconfirmed by the domestic inquiries, including the one held subsequent to the Court’s judgment. In 18 other cases, the Memorandum prepared by the Department for the Execution of Judgments indicates, “information is awaited as to whether the applicant has sought a reopening of the domestic proceedings against him.” 45