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ANGUELOVA v. BULGARIA JUDGMENT – PARTLY
DISSENTING OPINION OF JUDGE BONELLO
of Roma at the hands of Bulgarian police officers decided by the Court (see
Assenov and Others and Velikova). According to reports of intergovernmental organisations and human rights groups, the Bulgarian lawenforcement services boast of an unenviable primacy in racially prejudiced
ill-treatment of Roma.
Amnesty International, in a chillingly detailed account, focused on the
predilection displayed by police officers for savaging Roma. “Many of the
victims of beatings and other ill-treatment by police officers are Roma ...
Amnesty International expressed concern to the Bulgarian authorities about
two other incidents of mass beatings during police raids on Roma
neighbourhoods, five incidents of racial violence where Roma were
inadequately protected, five cases of deaths in suspicious circumstances and
nine incidents of torture and ill-treatment involving twenty-one victims.”
“The problem” adds the report, “is further compounded by a pattern of
impunity of law-enforcement officers responsible for human rights
violations” [“Bulgaria, Shooting, Death in Custody, Torture and Illtreatment”. AI Index: EUR 15/07/96]. On immunity of police officers from
prosecution, Amnesty International added that it was “concerned that police
impunity which prevails as Bulgarian authorities consistently fail to
investigate such incidents properly and impartially places at ever greater
risk of racist violence the most vulnerable ethnic community in Bulgaria”
[AI Index: EUR 01/06/97].
Another report emphasises that “Roma throughout Bulgaria have been
subjected to beatings and other ill-treatment by law-enforcement officers.
Amnesty International believes that in most instances such treatment is
racially motivated and is concerned that the ill-treatment of Roma is one of
the major human rights problems in Bulgaria” [“Bulgaria: Concerns about
Ill-treatment of Roma by Bulgarian Police”. AI Index: EUR 15/05/95].
6. It has not only been human rights groups that have sounded the alarm.
Intergovernmental organisations such as the Council of Europe and the
United Nations have also noted the problem. The Special Rapporteur on
Extrajudicial, Summary or Arbitrary Executions to the United Nations
Commission on Human Rights, too, “expresses concern about reports
indicating that persons belonging to the Roma minority [in Bulgaria] are the
main victims of police violence, in particular of violations to the right to
life” [Report of 25 January 1996 (E/CN.4/1996/4)]. The report by Alvaro
Gil-Robles, the Council of Europe's Commissioner for Human Rights, on
his visit to Bulgaria in December 2001 also contributes to the overall
perception of Roma as a disadvantaged and targeted minority in that
country.
7. The publication “Profession: prisoner. Roma in detention in Bulgaria”
also documents in detail the systems of conduct massively employed in
Bulgaria by law-enforcement officers, fortified by almost automatic