Abstract
This case illuminates important international aspects related to the declaration that was made by Azerbaijan against Article 11 of the Convention on Rights of Persons with Disabilities (hereafter the CRPD). This CRPD State party made reference to its inability to guarantee protecting persons with disabilities residing in Nagorno Karabakh until this area is freed from its occupation by Armenia. Bearing in mind the State-based model of enforcing the protection of human rights visa vie the growing urge to implement human rights obligations using extraterritorial accountability, the case of Chiragov and others v. Armenia of 16 June 2015, relates a controversial development. The case note discusses the way in which belligerent occupations have underpinned extending the enforcement of human rights obligations in times of armed conflict using the concept of extraterritorial accountability by the States parties. The case shows how the human rights court at Strasburg understands the application of rights to cases of belligerent occupation.
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