54 128. A similar approach was adopted by the European Court of Human Rights in Loizidou v. Turkey 152 (although in this case the question revolved around the possible control of a sovereign State over a State entity, rather than control by a State over armed forces operating in the territory of another State). The Court had to determine whether Turkey was responsible for the continuous denial to the applicant of access to her property in northern Cyprus and the ensuing loss of control over the property. The respondent State, Turkey, denied that the Court had jurisdiction, on the grounds that the act complained of was not committed by one of its authorities but, rather, was attributable to the authorities of the Turkish Republic of Northern Cyprus (“TRNC”). The Court dismissed these arguments and found that Turkey was responsible. In reaching the conclusion that the restrictions on the right to property complained of by the applicant were attributable to Turkey, the Court did not find it necessary to ascertain whether the Turkish authorities had exercised “detailed” control over the specific “policies and actions” of the authorities of the “TRNC”. The Court was satisfied by the showing that the local authorities were under the “effective overall control” of Turkey. 153 129. A substantially similar stand was recently taken in the Jorgic case by the Oberlandesgericht of Düsseldorf in a decision of 26 September 1997. 154 With regard to crimes committed in Bosnia and Herzegovina by Bosnian Serbs, the Court held that the Bosnian Serbs fighting against the central authorities of Sarajevo had acted on behalf of the FRY. To support this finding, the court emphasised that Belgrade financed, organised and equipped the Bosnian Serb army and paramilitary units and that there existed between the JNA and the Bosnian Serbs “a close personal, organisational and logistical interconnection ?Verflechtungg”, which was considered to be a sufficient basis for regarding the conflict as In Daley, on the other hand, the Claims Tribunal held Iran responsible for the expropriation of a car, for the five Iranian “Revolutionary Guards” who had taken the car were “in army-type uniforms” at the entrance of a hotel which had come “under the control of Revolutionary Guards” a few days before. (Daley v. Islamic Republic of Iran, Award No. 360-1-514-1, 18 Iran-U.S Claims Tribunal Reports, 1988, 232 at paras. 19-20). 152 Loizidou v. Turkey (Merits), Eur. Court of H. R., Judgement of 18 December 1996 (40/1993/435/514). 153 In its judgement, the Court stated the following on the point at issue here: “It is not necessary to determine whether, as the applicant and the Government of Cyprus have suggested, Turkey actually exercises detailed control over the policies and actions of the authorities of the “TRNC”. It is obvious from the large number of troops engaged in active duties in northern Cyprus [...] that her army exercises effective overall control over that part of the island. Such control, according to the relevant test and in the circumstances of the case, entails her responsibility for the policies and actions of the ‘TRNC’ [...]” (ibid., para. 56). 154 2 StE 8/96 (unpublished typescript; kindly provided by the German Embassy to the Netherlands and on file with the International Tribunal’s Library). Case No.: -94-1-A 15 July 1999