European Court of Human Rights delivers judgment in case concerning involuntary treatment and medication and oral hearing in the Administrative Court

On 9 December 2025, the European Court of Human Rights (ECtHR) delivered its judgment concerning Finland in a case about involuntary treatment and medication and failure to grant an oral hearing by the Administrative Court. The ECtHR unanimously held that there had been a violation of Article 5 (right to liberty and security) of the European Convention on Human Rights (ECHR), as the Administrative Court had not conducted an oral hearing in a matter concerning involuntary committal to psychiatric treatment. Regarding Article 8 (right to respect for private and family life) and Article 13 (right to an effective remedy), the ECtHR considered the application inadmissible.

In the case at issue, the applicant had been ordered to undergo involuntary psychiatric treatment. According to the applicant, she had also been administered medication against her will during the treatment. The applicant appealed the committal and medication to the Administrative Court, requesting that an oral hearing be held in court. The Administrative Court dismissed the appeals and the applicant’s requests for an oral hearing and did not examine the claims concerning medication. The Supreme Administrative Court refused to grant leave to appeal in the case.

In her application to the ECtHR, the applicant invoked Articles 8 and 13 of the ECHR, arguing that the involuntary administration of medication during treatment and the lack of an effective remedy to challenge the medication had breached her human rights. The applicant also relied on Article 6 (right to a fair trial), submitting that she had not received a fair trial because the Administrative Court repeatedly refused to hold an oral hearing and to hear witnesses proposed by the applicant.

As regards the allegations concerning the oral hearing, the ECtHR examined the application under Article 5 § 4 of the ECHR, as proceedings dealing with involuntary treatment involve deprivation of liberty. The ECtHR noted, among other things, that the applicant had been repeatedly admitted to and discharged from involuntary treatment at fairly short intervals, which may create some uncertainty about the necessity and justification of the measures. The applicant had also been subjected to involuntary medication against her will. Furthermore, the ECtHR noted that several years had passed since the applicant’s previous hearing, and that the hearing had concerned different proceedings than those at issue in the present case. The ECtHR considered that, in the applicant’s case, the principle of procedural fairness required that the applicant be heard in the Administrative Court either in person or, if necessary, through representation. The failure to grant her such a hearing undermined the effectiveness of the judicial review required under Article 5 §4 of the ECHR.

The ECtHR ordered the State to pay the applicant EUR 9,000 as just satisfaction for non-pecuniary damage and EUR 2,900 as compensation for legal costs.

As regards Articles 8 and 13, the ECtHR declared the application inadmissible because the applicant could no longer claim to be the victim of the violation complained of.

Read the judgment in the HUDOC database.