Abstract
The paper critically reviews the challenges facing the European Court of Human Rights when hearing claims being brought under Article 2 of the European Convention on Human Rights in relation to the phenomena of enforced disappearances as a result of the internal armed conflicts of Turkey and Chechnya. The paper traces the phenomenal and, oftentimes, controversial evolution of the associated jurisprudence and provides evidence of judicial disparities and inconsistencies that are not easily rationalised. Such inconsistencies suggest that whilst Strasbourg’s intention may be to ensure accountability in the face of adversity and human atrocities, its noble cause may be based on judicially unsubstantial foundations.
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