Anna Kudinova

12 November 2025

The Sarkozy case: is being alone in a cell a human rights violation?

Former President Nicolas Sarkozy was incarcerated at La Santé prison following his conviction. According to some reports, he was placed in isolation for security reasons.

The question arises: is being alone in a cell a human rights violation?

According to the case law of the European Court of Human Rights (ECHR), "solitary confinement is not prohibited in itself, but it can become a violation of Article 3 of the European Convention on Human Rights" in certain cases:

  • when the duration is extended without sufficient justification;
  • when there is no activity or social contact;
  • when there is no regular review or oversight of the measure.

Some examples from case law

  • Ramírez Sánchez v. France (2006): the Court held that total isolation amounted to inhuman treatment
  • A.T. v. Estonia (2018): isolation must be exceptional and subject to procedural safeguards
  • N.T. v. Russia (2020): even isolation shared by two detainees can violate Article 3 if the situation reproduces certain psychological effects

In summary

Being alone in a cell is not automatically contrary to human rights. However, "prolonged, unjustified isolation, without human contact, can constitute inhuman or degrading treatment (Article 3 of the European Convention on Human Rights)."

The Sarkozy case: is being alone in a cell a human rights violation? · Anna Kudinova