{"id":999,"date":"2019-04-17T06:07:35","date_gmt":"2019-04-17T06:07:35","guid":{"rendered":"https:\/\/laweuro.com\/?p=999"},"modified":"2021-09-22T12:09:59","modified_gmt":"2021-09-22T12:09:59","slug":"case-of-grigoryev-and-igamberdiyeva-v-russia","status":"publish","type":"post","link":"https:\/\/laweuro.com\/?p=999","title":{"rendered":"CASE OF GRIGORYEV AND IGAMBERDIYEVA v. RUSSIA (European Court of Human Rights)"},"content":{"rendered":"

THIRD SECTION
\nCASE OF GRIGORYEV AND IGAMBERDIYEVA v. RUSSIA<\/strong>
\n(Application no. 10970\/12)<\/em><\/p>\n

JUDGMENT
\nSTRASBOURG
\n12 February 2019<\/p>\n

This judgment is final but it may be subject to editorial revision.<\/p>\n

In the case of Grigoryev and Igamberdiyeva v. Russia,<\/p>\n

The European Court of Human Rights (Third Section), sitting as a Committee composed of:<\/p>\n

Helen Keller, President,
\nPere Pastor Vilanova,
\nMar\u00eda El\u00f3segui, judges,
\nand Fato\u015f Arac\u0131, Deputy Section Registrar,<\/p>\n

Having deliberated in private on 22 January 2019,<\/p>\n

Delivers the following judgment, which was adopted on that date:<\/p>\n

PROCEDURE<\/strong><\/p>\n

1.\u00a0\u00a0The case originated in an application (no. 10970\/12) against the Russian Federation lodged with the Court under Article 34 of the Convention for the Protection of Human Rights and Fundamental Freedoms (\u201cthe Convention\u201d) by two Russian nationals, Mr Yakov Aleksandrovich Grigoryev and Ms Kamola Dilmuratovna Igamberdiyeva (\u201cthe applicants\u201d), on 18 January 2012.<\/p>\n

2.\u00a0\u00a0The applicants were represented by Ms K. Mehtiyeva, a lawyer practising in Paris. The Russian Government (\u201cthe Government\u201d) were represented by Mr M. Galperin, Representative of the Russian Federation to the European Court of Human Rights.<\/p>\n

3.\u00a0\u00a0On 30 June 2017 notice of the complaints under Articles 5 \u00a7\u00a01, 10 and 11 was given to the Government and the remainder of the application was declared inadmissible pursuant to Rule 54 \u00a7 3 of the Rules of Court.<\/p>\n

4.\u00a0\u00a0The Government did not object to the examination of the applications by a Committee.<\/p>\n

THE FACTS<\/strong><\/p>\n

I.\u00a0\u00a0THE CIRCUMSTANCES OF THE CASE<\/p>\n

5.\u00a0\u00a0The first applicant (Mr Grigoryev) was born in 1984 and lives in Svetlogorsk. The second applicant (Ms Igamberdiyeva) was born in 1989 and lives in Kaliningrad.<\/p>\n

6.\u00a0\u00a0On an unknown date the second applicant notified the Kaliningrad authorities of her intention to hold a group public event on 12\u00a0December 2010 in Pobeda Square. The authorities replied that preparations for the New Year celebrations were planned on that day; they did not suggest an alternative venue. The second applicant did not challenge the authority\u2019s reply before the domestic courts. Both applicants decided to stage solo demonstrations near the monument to \u201cMother Russia\u201d instead; this did not require prior notification.<\/p>\n

7.\u00a0\u00a0According to the applicants, on 12 December 2010 the first applicant staged a solo demonstration holding a banner saying \u201cFreedom for Khodorkovskiy and Lebedev! We plead for a lawful judgment\u201d. After he had completed his demonstration and placed himself at a distance of some twenty metres, the second applicant held her own solo demonstration. She was wearing a T-shirt saying \u201cFreedom for Khodorkovskiy and Lebedev!\u201d She completed her demonstration in five minutes. Then the first applicant returned to the venue with his banner and remained there for about two minutes, until police officers took him to a police van. He was then taken to a police station and held there for over three hours.<\/p>\n

8.\u00a0\u00a0According to the Government, at 4 p.m. on 12 December 2010 the applicants participated in a group public event in the form of a \u201cpicket\u201d (\u043f\u0438\u043a\u0435\u0442\u0438\u0440\u043e\u0432\u0430\u043d\u0438\u0435) using visual props, namely a banner and a T-shirt. At\u00a04\u00a0p.m. the first applicant was taken to the Leninskiy district police station. Between 5.15 p.m. and 6.30 p.m. a duty officer drew up an administrative offence record in respect of the first applicant. He was accused of taking part in a group public event held without authorisation, an offence under Article 20.2 \u00a7 1 of the Code of Administrative Offences (hereinafter \u201cthe CAO\u201d). On 14 December 2012 the second applicant was called to the Leninskiy district police station, where she was accused of a similar offence, although it was classified under Article 20.2 \u00a7 2 of the CAO.<\/p>\n

9.\u00a0\u00a0The cases against the applicants were submitted to a justice of the peace of court circuit no. 2 of the Leninskiy District of Kaliningrad. The court ordered the police to submit a video recording showing the events of 12\u00a0December 2010. By two judgments of 3 March 2011 the justice of the peace found that the applicants had held solo demonstrations and had not breached the Public Events Act (hereinafter \u201cthe PEA\u201d), including its prior notification requirement applicable to group events. The court relied, inter\u00a0alia, on the video recording submitted by the police. The administrative cases against the applicants were discontinued for lack of the elements of the offences under Article 20.2 \u00a7\u00a7 1 and 2 of the CAO.<\/p>\n

10.\u00a0\u00a0The police lodged an appeal. On 16 May 2011 the Leninskiy District Court of Kaliningrad upheld the judgments. The appellate court also considered that it had not been confirmed that the applicants had in fact taken part in a group \u201cpicket\u201d.<\/p>\n

11.\u00a0\u00a0The applicants sought compensation of 100,000 roubles (RUB)[1] each for unlawful deprivation of liberty and violation of their right to freedom of expression by way of solo demonstration. By a judgment of 15\u00a0July 2011 the Tsentralniy District Court of Kaliningrad found that taking the first applicant to the police station had been unlawful, and awarded him RUB\u00a010,000 (equivalent to 250\u00a0euros (EUR) at the time) in respect of non-pecuniary damage. On 25 July 2011 the same court also granted the claims by the second applicant, having found that preventing her from staging a solo demonstration and consequently prosecuting her had been unlawful. The court also awarded the second applicant RUB 10,000 for non-pecuniary damage.<\/p>\n

12.\u00a0\u00a0The first applicant appealed against the judgment of 15 July 2011, complaining, inter alia, about the amount of the compensation and the first\u2011instance court\u2019s failure to make specific findings in relation to the violation of his freedom of expression on account of the police intervention in his solo demonstration. On 7 September 2011 the Kaliningrad Regional Court upheld the judgment. Relying on Article 27.1 \u00a7 2 of the CAO and Article\u00a01070 \u00a7 2 of the Civil Code, it ruled that it followed from the discontinuation of the CAO case that placing the first applicant under administrative escort and arrest had been unlawful under Russian law as well as \u201cunjustified\u201d (\u043d\u0435\u043e\u0431\u043e\u0441\u043d\u043e\u0432\u0430\u043d\u043d\u044b\u0435). The appellate court also considered that the interference with freedom of expression had been acknowledged by the declaration that taking the first applicant to the police station had been unlawful.<\/p>\n

13.\u00a0\u00a0The second applicant also appealed. On 21 September 2011 the Kaliningrad Regional Court upheld the judgment of 25 July 2011.<\/p>\n

II.\u00a0\u00a0RELEVANT DOMESTIC LAW AND PRACTICE<\/p>\n

14.\u00a0\u00a0For a summary of domestic law and practice concerning regulations relating to the conduct of public events, liability for breaches committed during such events, and administrative escort and arrest, see Lashmankin and Others, nos. 57818\/09 and 14 others, \u00a7\u00a7 216-312, 7 February 2017, and Novikova and Others v. Russia, nos. 25501\/07 and 4 others, \u00a7\u00a7 47-85, 26\u00a0April 2016.<\/p>\n

THE LAW<\/strong><\/p>\n

I.\u00a0\u00a0ALLEGED VIOLATIONS OF ARTICLES 5 \u00a7 1, 10 and 11 OF THE CONVENTION<\/p>\n

15.\u00a0\u00a0Referring to Articles 5 \u00a7 1, 10 and 11 of the Convention, the first applicant complained about being taken to the police station and held there, and the second applicant complained about being prosecuted for an administrative offence. Being master of the characterisation to be given in law to the facts of the case (see Radomilja and Others v. Croatia [GC], nos.\u00a037685\/10 and 22768\/12<\/a>, \u00a7 126, 20 March 2018), the Court considers that this complaint falls to be examined under Article 10 of the Convention, and Article 5 \u00a7 1 as regards the first applicant. The relevant parts of Articles\u00a05 and 10 read as follows:<\/p>\n

Article 5<\/strong><\/p>\n

\u201c1.\u00a0\u00a0Everyone has the right to liberty and security of person. No one shall be deprived of his liberty save in the following cases and in accordance with a procedure prescribed by law: …<\/p>\n

(c)\u00a0\u00a0the lawful arrest or detention of a person effected for the purpose of bringing him before the competent legal authority on reasonable suspicion of having committed an offence or when it is reasonably considered necessary to prevent his committing an offence or fleeing after having done so; …\u201d<\/p>\n

Article 10<\/strong><\/p>\n

\u201c1.\u00a0\u00a0Everyone has the right to freedom of expression. This right shall include freedom to hold opinions and to receive and impart information and ideas without interference by public authority …<\/p>\n

2.\u00a0\u00a0The exercise of these freedoms, since it carries with it duties and responsibilities, may be subject to such formalities, conditions, restrictions or penalties as are prescribed by law and are necessary in a democratic society, in the interests of national security, territorial integrity or public safety, for the prevention of disorder or crime …\u201d<\/p>\n

16.\u00a0\u00a0The Government argued that the domestic authorities had acknowledged the unlawfulness of the actions concerning prevention of both applicants from holding their solo demonstrations and their administrative prosecution, and the first applicant\u2019s being taken to the police station and held there for some time. Both applicants had been awarded reasonable compensation and thus their rights had been fully restored at the national level.<\/p>\n

17.\u00a0\u00a0The applicants submitted that they had staged solo demonstrations which did not require prior notification. The police had not explained in what manner the applicants\u2019 actions had constituted a breach of the Russian legislation or public order. Neither had they justified the first applicant\u2019s being taken to the police station and held there for three hours. The applicants further claimed that they had remained victims of a violation of their rights guaranteed by the Convention.<\/p>\n

A.\u00a0\u00a0Admissibility<\/strong><\/p>\n

18.\u00a0\u00a0First of all, the Court notes that the first applicant\u2019s complaint under Article 5 \u00a7 1 of the Convention was lodged on 18 January 2012, while his deprivation of liberty had ceased on 12 December 2010. However, following the discontinuation of the related administrative-offence proceedings the applicant brought civil proceedings for compensation that ended on 7 September 2011 and were partly successful (see paragraph\u00a011 above). The Court considers that those proceedings should be taken into account for the purposes of the six-month rule under Article 35 \u00a7 1 of the Convention. It follows that the first applicant has complied with this rule. This has not been contested, and the Court accepts that the same considerations are valid for the complaint under Article 10 of the Convention.<\/p>\n

19.\u00a0\u00a0The Court also reiterates that a decision or measure favourable to the applicant is not in principle sufficient to deprive him of his status as a \u201cvictim\u201d, unless the national authorities have acknowledged, either expressly or in substance, and then afforded redress for, the breach of the Convention right or freedom (see \u00d6zt\u00fcrk v. Turkey [GC], no. 22479\/93, \u00a7\u00a073, ECHR 1999\u2011VI). Redress so afforded must be appropriate and sufficient, failing which a person can continue to claim to be a victim of the violation (see Scordino v. Italy (no. 1) [GC], no. 36813\/97, \u00a7\u00a0181, ECHR\u00a02006\u2011V).<\/p>\n

20.\u00a0\u00a0The Court notes that both applicants claimed and received compensation at the domestic level before lodging an application before the Court. It considers that the issue of victim status is closely linked to the substance of the first applicant\u2019s complaints and must be joined to the merits.<\/p>\n

21.\u00a0\u00a0As regards the second applicant, it is common ground between the parties that she was not hindered and was able to complete her demonstration on 12 December 2010; the demonstration, by her own choice, lasted five minutes. It does not appear therefore that there was an intervention by the police in the exercise of her right to freedom of expression. As regards the subsequent prosecution of the second applicant, she was accused of an offence of an administrative nature (rather than of a criminal offence stricto sensu); that prosecution resulted in the discontinuation of the proceedings. The trial, which lasted from March until May 2011, was thus not overly long. The second applicant was not deprived of her liberty after the demonstration or during the trial; neither did she face other restrictions on her rights (compare D\u00f6ner and Others v. Turkey, no.\u00a029994\/02, \u00a7 88, 7 March 2017). The domestic courts acknowledged a violation of the second applicant\u2019s right to freedom of expression on account of her unlawful prosecution for an offence of an administrative nature, and awarded her compensation for non-pecuniary damage of EUR\u00a0250. Even assuming that there was an \u201cinterference\u201d and that the second applicant can still claim to be the victim of a breach of Article 10 of the Convention on account of the mere fact of being prosecuted, which lasted some time, albeit without incurring any other adverse consequences in connection with the prosecution (compare Dilipak v.\u00a0Turkey, no.\u00a029680\/05, \u00a7\u00a7\u00a044-51, 15 September 2015, and \u00c7\u00f6lge\u00e7en and Others v.\u00a0Turkey, nos.\u00a050124\/07 and 7 others, \u00a7\u00a7 39-40, 12\u00a0December 2017), the Court considers that this part of the application is manifestly ill-founded and must be rejected in accordance with Article 35 \u00a7\u00a7 3 (a) and 4 of the Convention.<\/p>\n

22.\u00a0\u00a0The Court notes that the first applicant\u2019s complaints under Article\u00a05 \u00a7\u00a01 and 10 of the Convention are not manifestly ill-founded within the meaning of Article 35 \u00a7 3 (a) of the Convention. It further notes that they are not inadmissible on any other grounds. They must therefore be declared admissible.<\/p>\n

B.\u00a0\u00a0Merits<\/strong><\/p>\n

23.\u00a0\u00a0The Court has previously found that the arrest and detention of protesters may constitute an interference with the right to freedom of expression (see Dilek Aslan v. Turkey, no.\u00a034364\/08, \u00a7 67, 20 October 2015, and the cases cited therein). In the present case the first applicant staged a solo demonstration holding a banner demanding a fair trial for two well\u2011known figures. The first applicant\u2019s demonstration was not interrupted. He thereby exercised, without hindrance, his right to freedom to \u201cimpart information and ideas\u201d and \u201cto hold opinions\u201d. However, his later being taken to the police station and prosecuted for an administrative offence were both related to his having expressed opinions and disseminated information, and therefore constituted \u201cinterference\u201d with his rights guaranteed under Article\u00a010 of the Convention. The fact that the prosecution for an administrative offence resulted in the discontinuation of the administrative proceedings against the first applicant does not alter that finding.<\/p>\n

24.\u00a0\u00a0The Court reiterates that the Contracting Parties, in accordance with the principle of subsidiarity, have the primary responsibility to secure the rights and freedoms defined in the Convention and the Protocols thereto (see Correia de Matos v. Portugal [GC], no.\u00a056402\/12<\/a>, \u00a7 116, 4\u00a0April 2018). The Court has no doubt that the domestic courts in the present case attempted, in good faith and to the best of their ability, to assess the level of suffering, distress, anxiety or other harmful effects sustained by the applicant. It reiterates that such an assessment should be carried out in a manner consistent with the domestic legal requirements and take into account the standard of living in the country concerned, even if that results in awards of amounts that are lower than those fixed by the Court in similar cases (see\u00a0Cocchiarella v. Italy\u00a0[GC], no.\u00a064886\/01, \u00a7 80, ECHR 2006\u2011V, and Vasilevskiy and Bogdanov v. Russia, nos. 52241\/14 and 74222\/14<\/a>, \u00a7\u00a023, 10\u00a0July 2018).<\/p>\n

25.\u00a0\u00a0However, even assuming that the domestic court\u2019s finding of unlawfulness regarding the first applicant\u2019s being taken to the police station from the site of his solo demonstration constituted, in substance, an acknowledgment of the violation of his freedom of expression, the Court is not satisfied that the amount of EUR 250 constituted adequate and sufficient redress in respect of the interference, which was both unlawful and disproportionate as indicated in paragraphs 26 and 27 below (see Novikova\u00a0and Others, cited above, \u00a7 218). The award was by no means comparable to what could be awarded under Article 41 of the Convention either under Article 5 \u00a7 1 or Article 10 of the Convention (see Scordino v.\u00a0Italy (no. 1), \u00a7\u00a7 181 and 202; Novikova and Others, \u00a7\u00a7 222-25 and 231, both cited above; Tsvetkova and Others v. Russia, nos. 54381\/08 and five others<\/a>, \u00a7 203, 10\u00a0April 2018; Fortalnov and Others v. Russia, nos.\u00a07077\/06 and 12 others<\/a>, \u00a7\u00a098, 26 June 2018; see also, mutatis mutandis, Vasilevskiy and Bogdanov, cited above, \u00a7 23). The Court further observes that although the domestic courts accepted that there had been no need to take the first applicant to the police station, they did not acknowledge the violation relating to the exercise of his freedom of expression (compare Centro\u00a0Europa 7 S.r.l. and Di Stefano v. Italy [GC], no. 38433\/09, \u00a7\u00a088, ECHR 2012). Thus, the first applicant remained a victim of the alleged violations under Articles 5 \u00a7 1 and 10 of the Convention when he lodged the application before the Court. The Government\u2019s objection as to the first applicant\u2019s victim status should be therefore dismissed.<\/p>\n

26.\u00a0\u00a0For its part, as to the merits of the complaint under Article 10 of the Convention, the Court does not discern any compelling reasons that justified taking the first applicant to the police station. The Court therefore concludes that he was a victim of, at the very least, disproportionate interference with his freedom of expression on account of his being taken to the police station.<\/p>\n

27.\u00a0\u00a0As to Article 5 \u00a7 1 of the Convention, the domestic courts acknowledged that the first applicant\u2019s being taken to the police station had been in breach of Russian law. The Court sees no reason to disagree.<\/p>\n

28.\u00a0\u00a0There have accordingly been violations of Articles 5 \u00a7 1 and 10 of the Convention in respect of the first applicant.<\/p>\n

II.\u00a0\u00a0APPLICATION OF ARTICLE 41 OF THE CONVENTION<\/p>\n

29.\u00a0\u00a0Article 41 of the Convention provides:<\/p>\n

\u201cIf the Court finds that there has been a violation of the Convention or the Protocols thereto, and if the internal law of the High Contracting Party concerned allows only partial reparation to be made, the Court shall, if necessary, afford just satisfaction to the injured party.\u201d<\/p>\n

A.\u00a0\u00a0Damage<\/strong><\/p>\n

30.\u00a0\u00a0Mr Grigoryev claimed 10,000 euros (EUR) in respect of non\u2011pecuniary damage.<\/p>\n

31.\u00a0\u00a0The Government contested the claims for non-pecuniary damage as excessive and unreasonable.<\/p>\n

32.\u00a0\u00a0Taking into account the nature and scope of the violations of Articles\u00a05 \u00a7 1 and 10 of the Convention and the domestic award, the Court awards Mr Grigoryev EUR 1,700 in respect of non-pecuniary damage, plus any tax that may be chargeable.<\/p>\n

B.\u00a0\u00a0Costs and expenses<\/strong><\/p>\n

33.\u00a0\u00a0Mr Grigoryev did not submit any claims under this head. Accordingly, there is no call to award him any sum on that account.<\/p>\n

C.\u00a0\u00a0Default interest<\/strong><\/p>\n

34.\u00a0\u00a0The Court considers it appropriate that the default interest rate should be based on the marginal lending rate of the European Central Bank, to which should be added three percentage points.<\/p>\n

FOR THESE REASONS, THE COURT, UNANIMOUSLY,<\/strong><\/p>\n

1.\u00a0\u00a0Joins the issue of the first applicant\u2019s \u201cvictim status\u201d to the merits of his complaints under Articles 5 \u00a7 1 and 10 of the Convention, and holds that the first applicant has victim status in relation to those complaints;<\/p>\n

2.\u00a0\u00a0Declares the complaints under Articles 5 \u00a7 1 and 10 of the Convention lodged by the first applicant admissible and the remainder of the application inadmissible;<\/p>\n

3.\u00a0\u00a0Holds that there have been violations of Articles 5 \u00a7 1 and 10 of the Convention in respect of the first applicant;<\/p>\n

4.\u00a0\u00a0Holds<\/p>\n

(a)\u00a0\u00a0that the respondent State is to pay the first applicant, within three months, EUR 1,700 (one thousand seven hundred euros), plus any tax that may be chargeable, in respect of non-pecuniary damage, to be converted into the currency of the respondent State at the rate applicable at the date of settlement;<\/p>\n

(b)\u00a0\u00a0that from the expiry of the above-mentioned three months until settlement simple interest shall be payable on the above amount at a rate equal to the marginal lending rate of the European Central Bank during the default period plus three percentage points;<\/p>\n

5.\u00a0\u00a0Dismisses the remainder of the applicant\u2019s claim for just satisfaction.<\/p>\n

Done in English, and notified in writing on 12 February 2019, pursuant to Rule\u00a077\u00a0\u00a7\u00a7\u00a02 and 3 of the Rules of Court.<\/p>\n

Fato\u015f Arac\u0131\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Helen Keller
\nDeputy Registrar\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 President<\/p>\n

_________________<\/p>\n

[1].\u00a0\u00a0Approximately 2,500 euros at the material time<\/p>\n

Facebook<\/a>Twitter<\/a>LinkedIn<\/a>Pinterest<\/a><\/div>","protected":false},"excerpt":{"rendered":"

THIRD SECTION CASE OF GRIGORYEV AND IGAMBERDIYEVA v. RUSSIA (Application no. 10970\/12) JUDGMENT STRASBOURG 12 February 2019 This judgment is final but it may be subject to editorial revision. In the case of Grigoryev and Igamberdiyeva v. Russia, The European…<\/p>\n

Read more →<\/a><\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[1],"tags":[],"class_list":["post-999","post","type-post","status-publish","format-standard","hentry","category-available-in-english"],"_links":{"self":[{"href":"https:\/\/laweuro.com\/index.php?rest_route=\/wp\/v2\/posts\/999","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/laweuro.com\/index.php?rest_route=\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/laweuro.com\/index.php?rest_route=\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/laweuro.com\/index.php?rest_route=\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/laweuro.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcomments&post=999"}],"version-history":[{"count":8,"href":"https:\/\/laweuro.com\/index.php?rest_route=\/wp\/v2\/posts\/999\/revisions"}],"predecessor-version":[{"id":16673,"href":"https:\/\/laweuro.com\/index.php?rest_route=\/wp\/v2\/posts\/999\/revisions\/16673"}],"wp:attachment":[{"href":"https:\/\/laweuro.com\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=999"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/laweuro.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcategories&post=999"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/laweuro.com\/index.php?rest_route=%2Fwp%2Fv2%2Ftags&post=999"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}