societies. Even in the most difficult circumstances, such as the fight against terrorism and organised crime, ECHR prohibits in absolute terms torture and inhuman or degrading treatment or punishment, irrespective of the victim’s conduct. In addition, the Court has noted that in respect of a person deprived of their liberty, recourse to physical force which has not been made strictly necessary by their own conduct diminishes human dignity and is in principle an infringement of Article 3 ECHR. One of the major root causes of widespread ill-treatment in Greece lies with the culture of impunity that pervades parts of the law enforcement sector, especially police and coast guard forces, as well as of the prosecutorial and judicial authorities. This requires a drastic overhaul of law enforcement overseeing and redress mechanisms, of the Greek criminal law itself, and of the awareness-raising and sensitisation of all actors of the national justice system. As regards migrants in particular, a number of international human rights reports, like those of CPT and of international NGOs,7 have recorded numerous cases of ill-treatment, including torture, suffered by migrants while under the control of Greek law enforcement officials. The continuous reporting of such incidents though was not accompanied by any major cases before the Strasbourg Court until 2003 when the first major application concerning a migrant’s ill-treatment by the police (Alsayed Allaham, see next section) was lodged. The 2007 judgment in Alsayed Allaham was followed by another judgment against Greece in 2012 in a more serious, factually, case, Zontul (see next section), concerning a migrant detainee’s torture through rape with a truncheon by a coast guard officer, and the lodging of a number of other similar applications by migrants that, as of early 2017, are pending in Strasbourg. The present paper aims to provide an analysis of the above first major judgments of the Strasbourg Court which usefully shed light on the underlying, long-standing systemic failures of the Greek rule of law. The author argues that these judgments are in fact only the tip of the iceberg. For this the paper looks into the process of supervision of these judgments’ execution by Greece, which is pending before the Council of Europe Committee of Ministers, as well as into alarming reports issued notably by CPT as well as by the Greek Ombudsman. The paper also highlights the question of racial violence that has not been so far the subject of analysis in the Court’s judgments concerning ill-treatment in Greece. However, a number of reports, especially the annual reports of the Greek Racist Violence Recording Network since 2012, record numerous cases of racist violence by law enforcement officials targeting migrants and the ineffective responses by the administrative and judicial authorities. Racial violence by state officials is not simply an affront to the victims’ human dignity but additionally to the fundamental principles of a European, democratic state like Greece whose primary obligation, under its own Constitution (Article 2§1), is “respect and protection of the value of the human being”. The situation represents a serious threat to the foundations of the rule of law and social cohesion in the country, given that law enforcement forces perform core state functions by upholding the law, and, at the same time, perform vital social and service functions.8 The paper concludes by certain major lines of thought and action which are required in order to effectively combat and eradicate migrant, but also nationals’, ill-treatment in Greek law enforcement. I. Strasbourg Court judgments indicating the systemic nature of migrant illtreatment and lack of adequate redress in Greece 7 See, inter alia, Amnesty International, A law unto themselves: A culture of abuse and impunity in the Greek police, 2014, available at: https://www.amnesty.org/en/documents/EUR25/005/2014/en/. 8 See Council of Europe Committee of Ministers, Recommendation Rec(2001)10 on the European Code of Police Ethics, preamble, recital 7, available at: https://search.coe.int/cm/Pages/result_details.aspx?ObjectID=09000016805e297e. 2 Electronic copy available at: https://ssrn.com/abstract=2921109