CHAPTER 4: UNLAWFUL KILLINGS AND MUTILATION OF THE DECEASED

Chapter 4. UNLAWFUL Killings AND MUTILATION OF THE DECEASED

CONTENTS

I. Introduction

II. Ample Documentation of Extrajudicial Killings

III. International Legal Framework on Extrajudicial Killings

IV. Key Findings

1. Killings of Civilians

The Elderly – Nearly Half of All Victims of Extrajudicial Killings

Wilful Killings of Disabled Civilians

2. Targeting of Former Combatants and POWs

3. Mutilation

4. Cruelty on Display

5. Impunity for Extrajudicial Killings

V. Conclusion

I. INTRODUCTION

During and following the 2020 Nagorno-Karabakh War, thousands of people, including civilians and soldiers, were killed. While some deaths may be permitted under international law, many of these killings were illegal. The University Network for Human Rights (UNHR or University Network) has closely reviewed over 150 killings of Armenian civilians, soldiers hors de combat (out of combat), and prisoners of war by Azerbaijani state forces, the majority of which are likely extrajudicial and warrant further investigation. This number is not intended to represent the totality of possible illegal killings, which is likely far greater, but rather to demonstrate the scope of cases reviewed for this report.¹ 

Many of these cases have involved ethnic Armenian civilian residents of Nagorno-Karabakh killed in their homes or villages by invading Azerbaijani forces. A substantial number of the civilians who have been extrajudicially killed were elderly and/or disabled and were unable to escape before Azerbaijani forces overtook their towns. In other cases, Azerbaijani forces have summarily executed Armenian soldiers who were injured, disarmed, and/or captured. Despite the November 2020 ceasefire agreement formally ending the war, such killings of Armenians have continued throughout the entire duration of our fact-finding activities. Nearly a third of the victims in this analysis were killed by Azerbaijani forces after the war's end.²

The ways in which many of the executions have been carried out have been particularly brutal. Azerbaijani forces have beaten, beheaded, stomped on, shot at point blank range, and mutilated civilians and soldiers alike, both before and after death. Azerbaijan's leadership has not only failed to investigate and hold the perpetrators of these abuses to account; they have condoned and encouraged the cruelest forms of violence against Armenians through prolific hate speech and racist propaganda. Further, the most egregious crimes have often been put on display by Azerbaijani soldiers themselves who have filmed and widely spread videos of summary executions on TikTok and Telegram. Members of the Azerbaijani military have also created stickers, memes, and emojis demeaning Armenians whom they have killed. Perpetrators have then sent these to victims' family members through social media feeds and messages. The circulation of graphic videos and images has directly threatened, humiliated, and instilled fear in families of people killed, as well as among Armenians more broadly. 

Subsequent to the killings, Azerbaijani authorities have unjustifiably retained the bodies of many of the victims for months before handing them over to Armenian authorities, prolonging and deepening the emotional suffering of victims' families. Meanwhile, Armenian families whose relatives are presumed or proven to have been killed extrajudicially have experienced significant obstacles in their search for information and in their efforts to recover their loved ones' remains. The Armenian government has failed to provide adequate administrative support to elderly and ill family members of victims as they navigate Armenian bureaucracy in search of information, accountability, and reparations.

Finally, there has been no accountability for these illegal killings.

The cases described below provide an overview of the methods by and frequency with which Azerbaijani forces have committed these killings and indicate that, far from isolated, incidental, or atypical, they are intentional consequences of deep-seated disregard for both Armenian lives and international law.

II. Ample Documentation of Extrajudicial Killings

Our analysis of extrajudicial killings relies in significant measure on secondary sources that have documented executions by Azerbaijan since the 2020 war, as well as firsthand interviews carried out by our team. We reviewed this information, visited some of the areas involved, and met with witnesses and community leaders to corroborate individual cases.

Evidence showing that Azerbaijan has committed extrajudicial killings of ethnic Armenians continues to amass over time. Armenia-based civil society organizations such as Open Society Foundations (OSF) and the International and Comparative Law Center have rigorously collected documentation of extrajudicial killings and other war crimes and human rights violations during and following the 2020 war. Both these groups have relied on primary sources, such as on-the-ground investigations and family or community member interviews, as well as corroborating sources such as audiovisual evidence and intelligence reports, to build their own archives of Azerbaijan’s willful killings of protected persons.³ Through their research, OSF and the International and Comparative Law Center have independently established that the number of such executions are certainly in the dozens but likely much higher. The Offices of the Human Rights Defenders in both Armenia and Nagorno-Karabakh have also conducted on-the-ground fact gathering and consulted with witnesses of extrajudicial killings.

Preeminent human rights watchdog and research institutions have likewise documented and verified firsthand testimony and social media postings of such killings. Amnesty International, for example, in a 2022 report titled “Last to Flee: Older People’s Experience of War Crimes and Displacement in the Nagorno-Karabakh Conflict,” outlined how older ethnic Armenians have been disproportionately subjected to violence, including war crimes, extrajudicial killings, and torture. Amnesty International conducted field research, interviewing and vetting witnesses to atrocity crimes and family members of the victims.⁴ In a separate report, Amnesty International analyzed and authenticated a number of videos posted on social media during the war that depicted decapitations and other executions further described below.⁵ Human Rights Watch has published at least two reports on various incidents of torture and extrajudicial killings by Azerbaijani soldiers.⁶ Additionally, international journalism outlets such as the BBC, the Guardian, and Bellingcat have investigated and corroborated individual incidents of extrajudicial killings.⁷ Finally, the International Crisis Group and the University of Southern California’s Dornsife Institute for Armenian Studies have aggregated evidence of killings from the aforementioned research and other military and governmental reports, officials’ statements, and news coverage.⁸

Among these existing sources, the University Network has found that at least 152 possible cases of extrajudicial killings have been individually identified and credibly investigated.⁹ UNHR’s database includes killings from September 2020 to March 2023. They involve victims aged nine to 82. Causes of death include drone strikes, sniper fire, short-range gunshots, decapitation, traumatic brain injury due to beating, and others. The circumstances surrounding death for a significant minority of cases are unknown, as bodies have been found killed, dismembered, and/or mutilated during search operations in areas following Azerbaijani occupation. Based on our research, it appears that Azerbaijan has yet to investigate, charge, or convict any members of its armed forces for involvement in the extrajudicial killings.¹⁰ And while many Armenians who are still unaccounted for – recorded missing or forcibly disappeared – are suspected to have been extrajudicially killed, those we were unable to cross-verify or for which we have not obtained witness or family-member testimony are not included in this report.¹¹

III. International Legal Framework on Extrajudicial Killings

Extrajudicial killings, also referred to as summary or arbitrary executions, are the deliberate killing of a person not authorized by a legal proceeding.¹⁴ Extrajudicial killings are a violation of international law, in particular the right to life, the most fundamental of human rights. The Office of the United Nations High Commissioner for Human Rights has maintained that the right to life is a “fountain” from which all other human rights flow.”¹⁵ It is enshrined in international human rights instruments, including the Universal Declaration of Human Rights, which states, “Everyone has the right to life, liberty and security of person,”   and the International Covenant on Civil and Political Rights, which asserts that “no one shall be arbitrarily deprived of their life.”¹⁶ 

The UN Human Rights Committee, the body of independent experts charged with interpreting and applying the International Covenant on Civil and Political Rights, has issued several official pronouncements regarding the nature and scope of the right to life, including its oft-cited General Comment No. 6. That document states that the right to life is the “supreme right from which no derogation is permitted even in time of public emergency which threatens the life of the nation.” It also emphasizes that States “should take measures not only to prevent and punish deprivation of life by criminal acts, but also to prevent arbitrary killing by their own security forces.”¹⁷ The Committee further maintains that States must provide reparations to victims when the right to life has been violated.¹⁸

IV. Key Findings

1. Killings of Civilians

During the war and following, the majority of the cases reviewed and cross-verified for this report involve civilians.¹⁹ Some of the most brutal and widely broadcast cases were killings of elderly people, sometimes along with their caregivers, who were taken from their homes. Many of the cases compiled were postwar killings, carried out after the November 10, 2020 ceasefire,²⁰ while the timing of other civilian deaths remains unknown. 

In Hadrut and elsewhere, several significant patterns emerged from our review of the cases. Elderly and disabled civilians appeared to have been incidentally or specifically targeted. In numerous cases, special brutality appeared to have been reserved for these most vulnerable civilians.

In one of the most widely documented extrajudicial killings throughout the conflict, Azerbaijani soldiers took 25-year-old Yuri Adamyan and 73-year-old Benik Hakobyan prisoner in an area of Hadrut in October 2020. In a pair of videos anonymously posted on Telegram, the two men are seen captured and executed by gunshot while sitting on a wall with their hands bound behind them and draped in the Armenia and Nagorno-Karabakh flags. Armenian authorities and neighbors of the two men identified them after the video circulated. While both Yuri and Benik were dressed in military camouflage, experts are unsure whether the men were civilians or soldiers.²¹

Mushegh Melkumyan, 83, was captured by Azerbaijani forces in early October 2020 after they invaded his town in Hadrut. Melkumyan remained in captivity without any contact with the outside world for the remainder of the month. Azerbaijan confirmed his captivity only after the International Committee of the Red Cross (ICRC) visited Melkumyan on October 26. When his body was returned to Armenia, Azerbaijan confirmed his date of death as October 29. Forensic exams following Mushegh’s extradition revealed sign of torture and death caused by a traumatic brain injury.²²

Arsen Gharakhanyan was a young man living in Moscow who returned to Nagorno-Karabakh to protect his parents, Sasha and Aida. Azerbaijani soldiers captured Gharakhanyan and Sasha after raiding their home in Hadrut; they released Sasha in December 2020, but not Gharakhanyan. After a few months with no information on Gharakhanyan’s whereabouts, a video surfaced on the internet showing Azerbaijani soldiers forcing Gharakhanyan to claim that Nagorno-Karabakh belongs to Azerbaijan and disparage Armenian Prime Minister Nikol Pashinyan, a common humiliation technique recounted by many surviving prisoners of war interviewed by UNHR. Another video circulated several days later in which Azerbaijani soldiers mocked Gharakhanyan and forced him to say hello to the city of Shusha, the Azerbaijani name for the city of Shushi (Shusha in Azeri) located in Nagorno-Karabakh.

Following the posting of these videos, the European Court of Human Rights asked Azerbaijan, on January 13, 2021, to provide information concerning Gharakhanyan’s whereabouts. Five days after this request, during a search for dead bodies in the Hadrut region, Gharakhanyan’s body was found in a freshly dug grave with gunshot wounds to his forehead and chin. During an interview with Human Rights Watch, Gharakhanyan's mother questioned,

Why did they kill our son? He wasn’t fighting in the war. He was unarmed. He just stayed to watch over his father. So, it’s a war, so they rounded him up – but the war ended, and they still didn’t let him go. They abused him, they filmed him, they posted those videos… and then killed him. Why?²³

Born in 1951, Gennady Petrosyan returned to his village in the Askeran region of Nagorno-Karabakh after evacuation in late October 2020 when he was captured by Azerbaijani soldiers.²⁴ His death was captured in two videos widely disseminated on social media and authenticated by Amnesty International. The first clip shows men in Azerbaijani military uniforms holding down a struggling shirtless man, while their colleague decapitates him with a knife. The video ends with a crowd of Azerbaijani soldiers cheering and clapping. In the second clip, the Azerbaijani men mock the deceased by placing his decapitated head onto a pig carcass. They then speak directly to their victim saying, “You have no honor, this is how we take revenge for the blood of our martyrs” and, “This is how we get revenge – by cutting heads.”²⁵

The bodies of David and Nina Davityan, an elderly married couple from a village in Hadrut that had come under Azerbaijani control in October 2020, were found during search operations in December of that year. Armenian authorities reported Nina’s body had been mutilated; her chest and hand had gunshot wounds; her head was separated from her body and its bones crushed.²⁶

Alvard Tovmasyan lived in a village in the Shushi region and was intellectually disabled. Her corpse, recovered in January 2021 during search operations and identified by family, revealed she had been tortured and mutilated. According to forensic analysis, she died from a blunt craniocerebral injury. The analysis further indicated that her feet, hands, left ear and the tip of her tongue were cut off while she was alive.²⁷

Armenian authorities found the bodies of Vahram Lalayan, Vardan Altunyan, and Slavik Galstyan in a village in Hadrut in December 2020. The latter two were both elderly pensioners. Lalayan had been decapitated and his wrists cut.²⁸

Aram,²⁹ a 43-year-old civilian, refused to leave his home in the region of Hadrut with the onset of the war. When Azerbaijani forces invaded the area, they beheaded Aram, as well as a 23-year-old Armenian soldier accompanying him, who lived in the same village. Their corpses were later discovered with their heads missing; the two men’s heads have still not been found.³⁰

Several significant patterns emerged from our review of the cases. Elderly and disabled civilians appeared to have been incidentally or specifically targeted. In numerous cases, special brutality appeared to have been reserved for these most vulnerable civilians.

The Elderly – Nearly Half of All Victims of Civilian Killings

Many of the above victims were pensioners. In fact, people over the age of 60 represent nearly half of the civilians likely extrajudicially killed who were reliably documented and collected here.³¹ Reports like Amnesty International’s “Last to Flee” and the Human Rights Defender of the Republic of Nagorno-Karabakh confirm that the elderly have been disproportionately victimized in the Azerbaijani’s assault on civilians in Nagorno-Karabakh.³² There are a number of possible explanations for this age distribution, among them a greater attachment to land and unwillingness to abandon it, as well as lesser physical ability to flee.

Another contributing factor may be what we found elsewhere, particularly in our research on torture of prisoners of war (POWs) – that Azerbaijani forces reserved special cruelty for those believed to have participated in the First Nagorno-Karabakh War. For example, Eduard Shakhkeldyan, 79, and his wife, Arega, lived in a village in Askeran and were both detained when Azerbaijani forces occupied their village. Arega told Human Rights Watch that in October,  

Their soldiers just ran into the house with those big automatic rifles, pointing their weapons at us, shouting, threatening. . . . I started crying, pleading with them not to hurt us, but they twisted my husband’s arms behind his back and led him out of the house. Then they pounced on me. I screamed, I tried to resist, I was telling them I won’t go anywhere, but they were yelling and pushing me, so they forced me out. I begged them to at least let me take some warm clothing, but they did not.³³

The two were detained together where Arega observed Azerbaijani soldiers beating her husband. “More soldiers were [at the detainment site] and one of them punched Eduard several times and kicked him with booted feet, yelling that he had surely taken part in the war 30 years earlier and this was his punishment for killing Azerbaijani people back then.”³⁴ They were then transported to a prison in Baku and separated. While imprisoned, guards told Arega that Eduard died in his sleep and took her to view his body. She remembers that his face was entirely bruised. Eduard's death certificate, issued by the Armenian authorities following an autopsy, listed his cause of death as “blunt brain injury, brain swelling, and acute disorder of vital brain function,” complications that could all be attributed to beatings, not natural causes.³⁵

Eduard Zhamharyan, 63, ran a small museum in Shushi. His daughter Sofia told Amnesty International that when Azerbaijani forces seized the city in November 2020, he was determined to stay in his home. “He didn’t believe that [the Azerbaijani forces] would get to Shusha,” Sofia reportedly said. “He also didn’t have electricity or water and couldn’t watch the news. I think if he had known, he would have [left].” Later that month, she learned local Nagorno-Karabakh authorities had received her father’s corpse from the Azerbaijanis. His head had a large open wound and his body was riddled with bullets that punctured his internal organs and appeared intended to maim him, according to an Armenian autopsy.³⁶ 

Ashot Munchyan was another elderly pensioner who remained in Shushi after it had been captured by the Azerbaijani military. His body was handed over to Armenian authorities in December 2020. He had been killed by gunshot, and his left ear had been cut off.³⁷

Edik Muradyan, 72, remained in his village in Hadrut during the invasion of Azerbaijani forces. His body was found in March of 2021; analysis by Armenian authorities dated his death to October 2020 and found that he died due to multiple bone fractures in his skull and throughout his body.³⁸

Volodya Aghabekyan, 82, refused to leave his home when violence escalated in the Askeran region. His son Telman stayed with him and joined a group of men defending their village. In October 2020, Azerbaijan initiated heavy shelling in the area, forcing the Armenian soldiers to abandon their posts. Telman told Amnesty International that no one was able to help his father escape. Volodya’s death was confirmed in November after his body was found in his home with gunshots to his head.³⁹

Elena Hakobyan lived with her husband Benik Hakobyan in Hadrut. Her body, found in January 2021, had been buried in the yard of her house. Her legs had been tied together with rope and she had been decapitated. Benik’s capture and killing are described in the breakout box above, and the circumstances of the execution of her disabled neighbors, Serjik and Ella Vardanyans, are described below.⁴⁰

Willful Killings of Disabled Civilians

Disabled civilians, including both those with physical and intellectual disabilities, represent a significant share of the victims of extrajudicial killings during the 2020 war and following its formal end. 

Borya (Boris) Baghdasaryan had a mental health condition and was cared for by his older brother, Baghdasar. When fighting began, Baghdasar told Amnesty International that he and his brother wanted to stay in their village in the Askeran district of Nagorno-Karabakh and help the Armenian soldiers by bringing them food. Azerbaijani soldiers entered the village in October 2020. Baghdasar ran and hid, but his brother did not. He described that Borya “didn’t understand what was happening, he just stood there… I heard him screaming and shouting at [the Azerbaijani soldiers], but I couldn’t hear what he was saying because I was already running away and trying to hide.”⁴¹ According to a prisoner of war captured from the same village and later repatriated, Valery Poghosyan, Borya’s beheaded body could later be seen on the ground.⁴² Armenian forces only recovered Boris’s body in April 2021, several months later. The cause of death was not definitive, but his niece Inara, who went to the morgue to identify him, confirmed his head was not attached to his body.⁴³ 

When Azerbaijani forces invaded the city of Hadrut in October 2020, a number of disabled civilians were among the at least a dozen they killed. Soldiers entered the home of Misha Movsisyan and fatally shot him in the head three times. His mother, Anahit, also suffered from gunshot wounds but survived. All three killed had mental disabilities.⁴⁴ 

Also from the city of Hadrut, Serjik and Ella Vardanyan had a number of health issues; Serjik specifically had diabetes, a past serious stroke, and an amputated leg. They lived with their son, who lost contact with his parents in October 2020. Their bodies were found in the yard of their house.⁴⁵ Serjik was half-buried, with some of his body dismembered and left on the ground.⁴⁶

Radik Stepanyan, 81, had physical disabilities that made fleeing from his village in Hadrut difficult even as fighting reached the region. His family and neighbors told Amnesty International he had been left behind and ultimately killed. Vahid Zoramush reportedly said,

His body was recovered in December 2020 with his head missing and legs broken.⁴⁸

2. Killings of Out-of-Combat Soldiers and Prisoners of War

Azerbaijani forces have also summarily executed members of another protected group of people: hors de combat, or soldiers who were no longer participating in active hostilities at the time of their killing due to choice or circumstance. Armenian soldiers who were injured, disarmed, or captured as prisoners of war were subjected to cruel and humiliating deaths, most often at the end of Azerbaijani rifles. More than half of the killings of out-of-combat soldiers analyzed here happened after the end of the 2020 war. Detailed below are several summary executions of out-of-combat soldiers since hostilities began in September 2020, though this section is by no means exhaustive.

In October 2020, Artur Manvelyan was wounded in combat near Mekhakavan. A video circulated on Telegram later that month showing an Azerbaijani soldier shooting Manvelyan from a close distance.⁴⁹ He was identified by his family. Open Society Foundations reported,

In another incident, Azerbaijani forces captured and beheaded Narek Babayan, and then called his family to tell them about his death. A photo of a dead and mutilated Babayan later appeared on his personal Instagram page.⁵¹

There are also a number of notable examples in which Armenian soldiers were executed as groups. In one case, Azerbaijani forces scouring the forest in an area near Hadrut following the signing of the trilateral ceasefire agreement found Karen Nersisyan, Hayk Harutyunyan, Albert Stepanyan, Grisha Grigoryan, Sasun Petrosyan, and Samvel Smbatov, and killed them on the spot.⁵² In another case, the bodies of Sargis Manukyan, Lyudvig Avdalyan, Senik Khurshudyan, and Husik Hovakimyan were captured on video being dragged out of a damaged medical transportation vehicle and thrown to the ground in a video that first appeared on Telegram in late October 2020. Azerbaijani soldiers disparage the men on camera. In another video posted a few days later, the half-naked bodies of the same four servicemen are again dumped to the ground, slammed with a shovel, and stomped in the faces. According to the International and Comparative Law Center, which analyzed the video, the bodies have signs they received medical treatment, further indicating the soldiers were captured and later killed.⁵³

What has been dubbed the Kovsakan massacre is one of two particularly egregious  instances of Azerbaijan extrajudicially killing Armenian soldiers en masse. In October 2020, 61 Armenian soldiers were deployed to Kovsakan in the Zangilan region when they were ambushed by Azerbaijani forces. According to two independent Armenian fact-finding reports on the incident, one by OSF in collaboration with Helsinki Citizens’ Assembly of Vanadzor, the Law Development and Protections Foundation, and “Protection of Rights without Borders”, and another by the International and Comparative Law Center, at least 17 Armenian soldiers were massacred by Azerbaijani forces – four in an initial execution and another 13 rounded up and killed later on.⁵⁴ Members of the Azerbaijani military captured much of these events on camera and posted them to social media, particularly Telegram, in October and November 2020. 

The Sev Lake executions, the second of these two especially brutal massacres, occurred in September 2022 in a border area split between the Syunik Province of Armenia and the Lachin District of Nagorno-Karabakh. This killing was also captured in a video authenticated by then-Human Rights Defender of Armenia Kristinne Grigoryan, Human Rights Watch, and Bellingcat.⁵⁵ In the video, Azerbaijani soldiers gather a group of Armenian soldiers and force them to the ground. The Armenian soldiers are unarmed. Soon thereafter, one Azerbaijani soldier begins firing his assault rifle at the group. A few other soldiers join and the close-range firing continues for at least 10 seconds. Thirty seconds into the video, the filmmaker takes his assault rifle and shoots several rounds at the body of an Armenian soldier already apparently dead on the ground. Bellingcat reported that at least nine were killed in this case.⁵⁶

3. Mutilation

Azerbaijani forces have also filmed the bodies of combatants killed in action, which they mutilated post mortem. It is not always apparent solely based on the content of the videos whether the mutilation occurred before or after death, but practices include chopping off limbs, carving messages across torsos, exposing victims' genitals and breasts, inserting digits or foreign objects into victims' mouths and empty eye sockets, severing victims’ heads, placing severed heads onto the bodies of animals, and other forms of horrific treatment.

Zara Amiryan and Lucin Prutyan⁵⁷were two female Armenian soldiers killed during Azerbaijan's September 2022 attacks on Armenia.⁵⁸ They appeared in a video clip of a carcass-strewn battle scene which was filmed and posted by Azerbaijani servicemen.⁵⁹ In the video, Amiryan appears stripped naked and placed trophy-like atop a pile of corpses as a soldier directed abuses toward the victims. Amiryan is shown mutilated, with an eyeball placed on her eyelid and a severed finger sticking out of her mouth. They carved the word “Yasma,” the code name for the Azerbaijani special forces, into her torso, with text written across her breasts and stomach. A stone has been placed in her eye socket and a severed finger in her mouth.

4. Cruelty on Display

A common feature of many of the aforementioned killings is their publicization across social media by members of the Azerbaijani military and public, if not the perpetrators themselves.⁶⁰ In many cases, Armenians have not only been executed, but have been shown mutilated or degraded on camera as well. 

 In a statement made after the posting of a summary killing of Armenian soldiers, the Armenian Ministry of Foreign Affairs claimed that “numerous videos regularly publicized by Azerbaijani users on social media demonstrate the war crimes, extrajudicial killings of Armenian prisoners of war, torture of Armenian servicemen, including women, and desecration of corpses committed by the Azerbaijani armed forces.”⁶¹ According to the Human Rights Defender of Armenia, whose office has collected and analyzed hundreds of videos showing Azerbaijani human rights abuses, all female victims of killings “were stripped down to their breasts and left on the field of combat with their chests stripped naked.”⁶² 

Among cases reviewed in this research, the most brazen instances of cruelty put on display include:

• An Azerbaijani soldier filmed his peers pinning Yuri Asriyan to the ground as he begs for mercy, reportedly saying, “For the sake of Allah, I beg you.” One of the soldiers can be heard saying, “Take this one,” as he hands a knife over to another, who then slices Asriyan’s throat.⁶³ “One of my nieces came and told me about the incident,” M., Yuri's sister, said in the UNHR interview. “She said Azeris made a video and aired it on TV. I couldn’t believe it and I didn’t see.”⁶⁴
• In two videos, Azerbaijani soldiers decapitate Gennady Petrosyan, who is shirtless, with a knife. The crowd of men claps and cheers loudly. Petrosyan’s head is then seen placed on the carcass of a pig, as soldiers say in the background,  “You have no honor, this is how we take revenge for the blood of our martyrs” and, “This is how we get revenge – by cutting heads.”⁶⁵
• Azerbaijani soldiers stomped on and beat four Armenian soldiers, Sargis Manukyan, Lyudvig Avdalyan, Senik Khurshudyan, and Husik Hovakimyan, post mortem in two different videos. In both clips, the Azerbaijanis are also heard making derogatory statements about them.⁶⁶
• One of the bloodiest massacres of the war in Kovsakan generated numerous videos distributed over social media of Armenian soldiers in various humiliating and degrading states: marching with their hands bound as Azerbaijani soldiers smile into their front facing camera, lined up in a row while sitting on the ground, shot at point-blank range while laying face down, presumably already executed, among others.
• In the video displaying the mutilated corpse of the female soldiers described above, the man filming comments, “Look at the bitch, there are two women. She became a rock.” The soldier filming later stomps on the chest of Prutyan, who is also stripped naked. She was reportedly returned to Armenia in the same condition in which she is seen in the video, with her underwear hanging off her hand. In a separate video from the same scene, the body of another woman, later identified as a medical nurse, is seen wearing only underwear.⁶⁷
• Degrading videos of Arsen Gharakhanyan on the internet were the first news his family learned of his whereabouts and status after he was captured by Azerbaijani forces. In one, Azerbaijani soldiers force the young Armenian soldier to say Nagorno-Karabakh belongs to Azerbaijan; in another, Azerbaijanis mock him and force him to say hello to the Nagorno-Karabakh city of Shushi. His body was later found buried shortly after the videos surfaced online.⁶⁸ 

Though the exact circumstances of most of the videos referenced in this report have yet to be verified, their existence and proliferation, and the frequent celebratory rhetoric within and surrounding them, strongly suggests that inhumanity was not incidental, but rather the point.

The captions and comments on much of this content indicate as much. Some of these videos, according to analysis by the Human Rights Defender of Armenia, were posted on social media accounts dedicated to mocking and denigrating Armenians. One example is the Telegram channel Khacherubka, which is a derivative of two Russian words: “Khach,” an anti-Armenian epithet, and “Rubka,” meaning “felling.” The comment sections on this account reflect hatred toward Armenian captives and Armenians in general.⁶⁹ In another example, a popular VK account called Polygon Azerbaijan that created and spread content to help fight the “information war” during the 2020 conflict regularly shared graphics featuring rats as Armenian soldiers in response to announcements of the death or serious injury of Armenian military personnel. Analysis by the Promise Institute for Human Rights determined this content, which continued well after the end of the war, was regularly reposted on Azerbaijani Twitter accounts, message boards, and news sites.⁷⁰ In a final example, on videos depicting the September 2022 Sev Lake executions, journalist Lindsey Snell documented how the Azerbaijani comments “[exemplify] how atrocities against Armenians are celebrated in Azerbaijani society,” with some of them gleefully lauding the killings and one calling for the soldiers involved to be given monetary awards and medals for their bravery.⁷¹ In fact, Kamil Zeynalli, one of the Azerbaijani soldiers identified as being involved in the murder of Yuri Asriyan, was awarded two recognitions by private associations for his participation in the war.⁷²

This pernicious animosity towards Armenians has normalized violence against them in Azerbaijani culture, the Human Rights Defender of Armenia has written. These videos, in which such violence is performed without remorse, are widely distributed and gloried – only further perpetuating the dehumanization of Armenians.

This cruelty has gone a step further than online virality, with Azerbaijani soldiers using social media to terrorize the families of Armenians they have killed. The case of Narek Babayan is one instance, in which Azerbaijani forces, after beheading him, called his family to tell them about his death and posted a photo of his dead and mutilated body on his personal Instagram page.⁷⁴

5. Impunity for Extrajudicial Killings

Azerbaijan has taken very few steps towards accountability for suspected extrajudicial killings, wartime or post-ceasefire. 

In October 2022, Azerbaijan’s Prosecutor General’s Office announced it had started an investigation into the “video footage of Azerbaijani servicemen allegedly shooting at detained Armenian saboteurs” to verify the video's authenticity, time and location of the event, and the “identity of the servicemen shown on them.” The Office also stated that “[based on the results, measures provided for by law will be taken.”⁷⁵ The US State Department reported, “Later that month, the Ministry of Foreign Affairs stated that criminal cases were opened concerning perpetrators of crimes portrayed in the video, with no further details.”⁷⁶ Our researchers were not able to find any   information regarding the results of that investigation, and the Office does not appear to have initiated any investigations into other instances of extrajudicial killings. 

Given the failure of Azerbaijani authorities, the European Court of Human Rights (ECHR) and the International Court of Justice (ICJ) have taken initial steps towards holding Azerbaijan accountable for extrajudicial killings. In a September 2020 interim measures ruling, the ECHR “called upon both Azerbaijan and Armenia to refrain from taking any measures, in particular military action, which might entail breaches of the Convention and violate rights of the civilian population, including putting their life and health at risk, and to comply with their engagements under the Convention, notably in respect of Article 2 (right to life) and Article 3 (prohibition of torture and inhuman or degrading treatment or punishment).”⁷⁷ On September 22, 2023, the ECHR also issued interim measures obligating Azerbaijan to “refrain from taking any measures which might entail breaches of their obligations under the [European Convention], notably Article 2 (right to life) and Article 3 (prohibition of torture and inhuman or degrading treatment or punishment).”⁷⁸ The International Court of Justice, in a December 2021 opinion, took note of a joint statement issued by several UN human rights special rapporteurs expressing grave concern “at allegations that prisoners of war and other protected persons have been subjected to extrajudicial killing, enforced disappearance, torture and other ill-treatment.”⁷⁹ In light of this, the Court ordered Azerbaijan to “[p]rotect from violence and bodily harm all persons captured in relation to the 2020 Conflict who remain in detention, and ensure their security and equality before the law.”⁸⁰

Beyond these preventive efforts of the ECHR and ICJ, there has been little formal investigation or prosecution for extrajudicial killings in international fora, due in part to the numerous obstacles faced by human rights lawyers trying to move the needle on complaints. The Armenian Legal Center for Justice and Human Rights, for example, in partnership with the International and Comparative Law Center, has announced that it has brought cases on 19 Armenians killed in 10 separate incidents while in the custody of Azerbaijani forces or in prison in Azerbaijan to the ECHR.⁸¹ As of December 2023, there have been no updates from the Court on these cases.⁸²

In addition to the measures taken by international courts, the UN Human Rights Council-appointed Special Rapporteur on Extrajudicial, Summary or Arbitrary Executions stated in September 2023 that “Azerbaijan must . . . promptly investigate alleged or suspected violations of the right to life reported in the context of its later military offensive . . . during which dozens of people, including peacekeepers, were killed.”⁸³ In addition, the European Parliament issued a resolution calling on the European Union to adopt targeted sanctions against the Azerbaijani government officials responsible for multiple ceasefire violations and human rights abuses in Nagorno-Karabakh.⁸⁴ The resolution also described the conflict as a gross violation of international law and called for investigations into abuses committed by Azerbaijani forces that could constitute war crimes.

Conclusion

During and following the 2020 Nagorno-Karabakh War, Azerbaijani forces have committed killings of Armenian civilians, soldiers hors de combat, and prisoners of war. A substantial number of the civilians who have been killed are elderly and/or disabled who would not or could not escape before Azerbaijani forces overtook their towns. In other cases, Azerbaijani forces have summarily executed Armenian soldiers who were injured, disarmed, and/or captured. The most egregious cases of extrajudicial killings have often been put on display by Azerbaijani soldiers themselves who have filmed and widely spread videos of these killings on social media. The circulation of graphic videos and images has directly instilled fear, threatened, and humiliated families of people killed, as well as other Armenians. 

The actions of the Azerbaijani military described here violate the paramount human right to life, and the associated responsibilities to investigate and prosecute possible extrajudicial killings and hold those responsible to account. The widespread nature and cruelty of these killings suggest a systematized practice within the Azerbaijani state forces, rather than isolated or fringe cases. 

Additionally, the impacts of these extrajudicial killings are felt not only by the friends and families of individual victims. The terror of ruthless slaughter reaches both those victimized directly and those afraid such a death  become their fate. This abuse is therefore related to forced displacement: the sister of a civilian beheaded by Azerbaijani soldiers explained that after you hear and see such stories, when the soldiers approach your village, “All you can think about is escape.”

Endnotes:

 1. This calculation is based on UNHR review of credible reporting, described in further detail below.

2. This report focuses largely on post-ceasefire violations. Wartime violations are mentioned insofar as accountability is still wanted.

3.  “The Fact-Finding Group interviewed lawyers, families, and, where possible, the repatriated POWs (the victims of abuses). In the course of the fact-finding mission, the members of the Group members interviewed four former POWs who were repatriated in December 2020. The cases presented below are corroborated with video evidence taken by the perpetrators or their colleagues and posted on social networks by members of the Azerbaijani Armed Forces or affiliated users, including on Telegram channels Caliber, Kolorit 18+, Karabah_News, as well as Facebook, Instagram and TikTok. Corroboration was also obtained via an interview with the lawyer representing the victims and their families before the ECHR, and via interviews given by other repatriated POWs to media in relation to the same or related facts. The information presented in this report is also corroborated by the findings of the reports of the Human Rights Defender of the Republic of Nagorno-Karabakh, Human Rights Watch, Amnesty International, open-source investigations conducted by international media, as well as statements of international organizations.” Open Society Foundations Armenia et al., “Human Rights Violations During the 44-Day War in Artsakh: Fact Finding Report” (Yerevan: Helsinki Citizens’ Assembly of Vanadzor, the Law Development and Protections Foundation, “Protection of Rights without Borders” Non-governmental Organization, 2022), 50. https://www.osf.am/wp-content/uploads/2022/06/Fact-Finding-Report_FINAL_web.pdf

4.  Amnesty International. 2022. “Armenia: Last to flee: Older people’s experience of war crimes and displacement in the Nagorno-Karabakh conflict.” Amnesty International. https://www.amnesty.org/en/documents/eur54/5214/2022/en/.

5. “Armenia/Azerbaijan: Decapitation and War Crimes in Gruesome Videos Must Be Urgently Investigated,” Amnesty International, December 10, 2020, https://www.amnesty.org/en/latest/news/2020/12/armenia-azerbaijan-decapitation-and-war-crimes-in-gruesome-videos-must-be-urgently-investigated/.

6. Lokshina, “Survivors of Unlawful Detention in Nagorno-Karabakh Speak out about War Crimes.”; Human Rights Watch. 2022. “Video Shows Azerbaijan Forces Executing Armenian POWs.” Human Rights Watch. https://www.hrw.org/news/2022/10/14/video-shows-azerbaijan-forces-executing-armenian-pows.

7. Human Rights Watch. 2022. “Video Shows Azerbaijan Forces Executing Armenian POWs.” https://www.hrw.org/news/2022/10/14/video-shows-azerbaijan-forces-executing-armenian-pows.; Atanesian, Grigor, and Strick, Benjamin. 2020. “Nagorno-Karabakh conflict: 'Execution' video prompts war crime probe.” BBC. https://www.bbc.com/news/world-europe-54645254.; Roth, Andrew. 2020. “Two men beheaded in videos from Nagorno-Karabakh war identified.” The Guardian. https://www.theguardian.com/world/2020/dec/15/two-men-beheaded-in-videos-from-nagorno-karabakh-war-identified.; Waters, Nick. 2020. “An Execution in Hadrut - bellingcat.” Bellingcat. https://www.bellingcat.com/news/rest-of-world/2020/10/15/an-execution-in-hadrut-karabakh/.; Gonzales, Carlos. 2022. “An Execution Near Sev Lake - bellingcat.” Bellingcat. https://www.bellingcat.com/news/2022/10/20/an-execution-near-sev-lake-armenia-azerbaijan/.

8.“The Nagorno-Karabakh Conflict: A Visual Explainer,” October 27, 2020, https://www.crisisgroup.org/content/nagorno-karabakh-conflict-visual-explainer; Emil Sanamyan, “Legal Appeals Filed Over Armenians Executed in Azerbaijani Custody,” USC Institute of Armenian Studies (blog), May 3, 2021, https://armenian.usc.edu/appeals-filed-over-captured-armenians-executed-in-azerbaijani-custody/.

9. However, calculating the exact number of wartime and postwar extrajudicial killings of civilians and other protected persons is an inherently difficult and arguably impossible task, especially at this stage of conflict; any tally should be taken with caution. In general, this difficulty exists because the evidence  distinguishing legal killings from illegal killings in conflict contexts is often difficult to obtain, especially from afar or after the fact, as such distinctions are often idiosyncratic and context-dependent. Without the details of the circumstances surrounding the vast majority of wartime deaths, the issue of extrajudicial killings is likely to be far undercounted. This difficulty is exacerbated in the present case by specific failings and deficiencies of the parties involved. Due to reporting issues and a lack of transparency by Azerbaijan surrounding wartime casualties, Armenia and the International Committee of the Red Cross (ICRC)’s inability to account for all disappeared persons, unrecovered remains, unsuccessful DNA testing, and family resistance, reports often cannot ascertain the extent of Azerbaijan’s engagement in extrajudicial executions. Additionally, Azerbaijan’s aggressive blockade at the Lachin Corridor has made independent evidence-gathering within Nagorno-Karabakh nearly impossible since December 2022.

10. See “Impunity for Extrajudicial Killings” below.

11. This analysis collated credible reports of possible extrajudicial killings. Cases investigated by organizations that conducted independent on-the-ground fact-finding and/or work with the families of victims were deemed credible; cases documented and investigated by independent international organizations (through open source methods and others) in tandem with local news reporting were also deemed credible.

12. Interviewee requested not to be named.

13. M., interview with UNHR, Sis, July 21, 2023.

14. UN Office of the High Commissioner for Human Rights (OHCHR), Fact Sheet No. 11 (Rev.1), Extrajudicial, Summary or Arbitrary Executions, October 1997, available at: https://www.ohchr.org/sites/default/files/Documents/Publications/FactSheet11rev.1en.pdf

15. Ibid.

16. UN General Assembly, The Universal Declaration of Human Rights, art. 3, 10 December 1948, United Nations, available at: https://www.ohchr.org/en/human-rights/universal-declaration/translations/english [hereinafter “UDHR”]; UN General Assembly, International Covenant on Civil and Political Rights, art. 6, 16 December 1966, United Nations, available at: https://www.ohchr.org/en/instruments-mechanisms/instruments/international-covenant-civil-and-political-rights [hereinafter ICCPR].

17. UNHRC, General Comment No. 6: Article 6 (Right to Life), 16th Sess, adopted 30 June 1982, U.N. Doc. HRI/GEN/1/Rev.1 at 6 (1994), available at: https://documents-dds-ny.un.org/doc/UNDOC/GEN/G94/189/63/PDF/G9418963.pdf?OpenElement

18. UN General Assembly, Basic Principles and Guidelines on the Right to a Remedy and Reparation for Victims of Gross Violations of International Human Rights Law and Serious Violations of International Humanitarian Law, principle 20, 15 December 2005, United Nations, available at: https://www.ohchr.org/en/instruments-mechanisms/instruments/basic-principles-and-guidelines-right-remedy-and-reparation

19. 95 of 152. This number includes civilians killed by illegal munitions in residential areas during the 2020 war. This report does not explore this issue in further detail for a number of reasons, including evidence supporting that Armenian and Nagorno-Karabakh forces violated international humanitarian law regarding illegal munitions on civilians as well

20. 18 of 95.

21. Atanesian & Strick, “Nagorno-Karabakh Conflict: ‘Execution’ Video Prompts War Crime Probe”; Waters, “An Execution in Hadrut.”

22.  Human Rights Defender of the Republic of Artsakh. 2021. “Interim Report on the Cases of the Killing of Civilians in Artsakh by the Armed Forces of Azerbaijan.” Artsakh Ombudsman. https://artsakhombuds.am/en/document/785.

23. Lokshina, “Survivors of Unlawful Detention in Nagorno-Karabakh Speak out about War Crimes.”

24. Human Rights Defender of the Republic of Artsakh. “Interim Report on the Cases of the Killing of Civilians in Artsakh.”

25. Amnesty International. 2020. “Armenia/Azerbaijan: Decapitation and war crimes in gruesome videos must be urgently investigated.” Amnesty International. https://www.amnesty.org/en/latest/press-release/2020/12/armenia-azerbaijan-decapitation-and-war-crimes-in-gruesome-videos-must-be-urgently-investigated/.

26. NEWS. 2020. “80-year-old Nina Davtyan, who stayed in her house in Vardashat village, was killed by Azerbaijani soldiers.” NEWS.am. https://news.am/arm/news/619764.html.; Musheghyan, Trdat. 2022. “Passport Photos Never Used: Murdered Artsakh Couple Buried Far from Home.” hetq. https://hetq.am/en/article/141138.

27. Human Rights Defender of the Republic of Artsakh, “Interim Report on the Cases of the Killing of Civilians in Artsakh”; Anya Sarkisova, Gayane Hovsepyan, and Tirayr Muradyan, “Falling Under the Rock,” Hetq, June 4, 2021, https://hetq.am/hy/article/131530; International and Comparative Law Center, “Extrajudicial Killings and Missing Persons - Artsakh 2020.”

28. Human Rights Defender of the Republic of Artsakh, “Interim Report on the Cases of the Killing of Civilians in Artsakh”; Armenian Legal Center for Justice & Human Rights. 2021. “Armenian Legal Center for Justice & Human Rights announces legal action before the European Court for POWs murdered by Azerbaijan.” The Armenian Weekly. https://armenianweekly.com/2021/08/10/armenian-legal-center-for-justice-human-rights-announces-legal-action-before-the-european-court-for-pows-murdered-by-azerbaijan/.

29. Name has been changed to protect privacy and security.

30. International and Comparative Law Center, “Extrajudicial Killings and Missing Persons - Artsakh 2020.”

^{31. 43 of 95}

32. “According to information Amnesty International obtained from the Office of the Human Rights Defender of Nagorno-Karabakh, more than half of the 48 documented civilians killed during the 44-Day War were elderly persons, at least 30 of whom were unable or unwilling to flee before Azerbaijani forces took their town. The relatives who survived them, some of whom spoke to University Network researchers, think that their loved ones did not believe that they would be killed.” (Amnesty International, “Armenia: Last to Flee”; Amnesty International, “Decapitation and War Crimes in Gruesome Videos Must Be Urgently Investigated.”) According to the Human Rights Defender of the Republic of Nagorno-Karabakh, 39 of the 80 civilians killed between September 2020 and December 2021 were over the age of 63. (Human Rights Defender of the Republic of Artsakh, “Interim Report on the Cases of the Killing of Civilians in Artsakh,” Infographic 5. Killed civilians by age).

33. Lokshina, “Survivors of Unlawful Detention in Nagorno-Karabakh Speak out about War Crimes.”

34. Ibid.

35. Ibid.

36. Amnesty International, “Armenia: Last to Flee,” 18.

37. Human Rights Defender of the Republic of Artsakh, “Interim Report on the Cases of the Killing of Civilians in Artsakh”; International and Comparative Law Center, “Extrajudicial Killings and Missing Persons - Artsakh 2020.”

38. Human Rights Defender of the Republic of Artsakh, “Interim Report on the Cases of the Killing of Civilians in Artsakh.”

39. Amnesty International, “Armenia: Last to Flee,” 21.

40. Lokshina, “Survivors of Unlawful Detention in Nagorno-Karabakh Speak out about War Crimes.” Human Rights Defender of the Republic of Artsakh, “Interim Report on the Cases of the Killing of Civilians in Artsakh”; International and Comparative Law Center, “Extrajudicial Killings and Missing Persons - Artsakh 2020.”

41. Amnesty International, “Armenia: Last to Flee,” 19-20.

42. International and Comparative Law Center, “Extrajudicial Killings and Missing Persons - Artsakh 2020.”

43. Amnesty International, “Armenia: Last to Flee,” 20.

44. Ibid.

45. Ibid.

46. International and Comparative Law Center, “Extrajudicial Killings and Missing Persons - Artsakh 2020.”

47.  Amnesty International, “Armenia: Last to Flee,” 16.

48. International and Comparative Law Center, “Extrajudicial Killings and Missing Persons - Artsakh 2020,” 2022. Non-public database.

49. Ibid.

50. Open Society Foundations Armenia,“Human Rights Violations During the 44-Day War in Artsakh,” 55.

51. Armenian Legal Center for Justice & Human Rights. “Armenian Legal Center for Justice & Human Rights announces legal action before the European Court for POWs murdered by Azerbaijan.”

52. Ibid.

53. International and Comparative Law Center, “Extrajudicial Killings and Missing Persons - Artsakh 2020.”

54. Open Society Foundations Armenia,“Human Rights Violations During the 44-Day War in Artsakh,” 50; “The Kovsakan Incident Report” (Yerevan: International and Comparative Law Center, 2021).

55. Grigoryan, Kristinne. 2023. “The statement of the Defender on the video of the execution of Armenian PoWs by the Azerbaijani armed forces.” Facebook. https://www.facebook.com/100069268237249/posts/pfbid027NbDrxxZCJaV2cRMuqogZJdJJ8PkQUUoM6gHaBmigpe2A3UpodZMR6qaRgBJVfy9l/.; Human Rights Watch, “Video Shows Azerbaijan Forces Executing Armenian POWs”; Gonzales, “An Execution Near Sev Lake”

56. Gonzales, “An Execution Near Sev Lake.”

57. Names have been changed to protect privacy and/or security.

58. “Ad Hoc Report,” The Human Rights Defender of Armenia.

59. Ibid. UNHR researchers independently viewed the footage.

60. AzerWarCrimes.org has created an archive of videos posted to various platforms. Go to https://azeriwarcrimes.org/atrocities/ to view their collection on “Willful killing, mutilation, torture, and inhuman treatment of Armenians by Azerbaijani forces.”

61. Ministry of Foreign Affairs of the Republic of Armenia. 2022. “Statement of the Foreign Ministry of Armenia on the war crimes committed by the armed forces of Azerbaijan.” Ministry of Foreign Affairs. https://www.mfa.am/en/interviews-articles-and-comments/2022/10/02/Statement_PoWs/11661.

62. “Ad Hoc Report,” The Human Rights Defender of Armenia; Julhakyan, Arusyak. 2023. “Opening of the sitting No. 3.” Parliamentary Assembly. https://pace.coe.int/en/verbatim/2023-01-24/am/en.

63. Amnesty International, “Decapitation and War Crimes in Gruesome Videos Must Be Urgently Investigated.”

64. M., interview.

65. Amnesty International, “Decapitation and War Crimes in Gruesome Videos Must Be Urgently Investigated.”

66. Armenian Legal Center for Justice & Human Rights. “Armenian Legal Center for Justice & Human Rights announces legal action before the European Court for POWs murdered by Azerbaijan.”

67. “Ad Hoc Report,” The Human Rights Defender of Armenia.; Azeri War Crimes. 2022. “Desecration of female Armenian soldier by Azerbaijani troops - AzeriWarCrimes.ORG.” Azeri War Crimes. https://azeriwarcrimes.org/2022/09/19/desecration-of-female-armenian-soldier-by-azerbaijani-troops/.

68. Armenian Legal Center for Justice & Human Rights. “Armenian Legal Center for Justice & Human Rights announces legal action before the European Court for POWs murdered by Azerbaijan.”

69. “Ad Hoc Report,” The Human Rights Defender of Armenia.

70. Dardari, Aya, Nicholas Levsen, Ani Setian, and Jessica Peake. 2021. “Social Media, Content Moderation, and International Human Rights Law: The Example of the Nagorno-Karabakh/Artsakh Conflict.” pg. 27-35. The Promise Institute for Human Rights. https://promiseinstitute.law.ucla.edu/wp-content/uploads/2022/05/Social-Media-Content-Moderation-and-Internationals-Human-RIghts-Law.pdf.

71. Snell, Lindsey. 2022. “This Response to the Latest AZ War Crime Video Exemplifies How Atrocities against Armenians Are Celebrated in Azerbaijani Society.” Twitter. https://twitter.com/LindseySnell/status/1576624123953881089.

72. “As for the medals, the "National Army-100" medal was founded by the Public Union of Veterans of the Patriotic War of Azerbaijan, and the "For the Motherland" medal was founded by the Public Union of the Disabled, Veterans and Martyrs' Families of Azerbaijan Karabakh War. These medals are not considered state awards. Kamil Zeynalli also thanked the public association in his post.” (ElMedia. 2021. “Was Kamil Zeynalli given a medal or not? - FactCheck.” ElMedia. https://elmedia.az/xeber/kamil-zeynalliya-medal-verilib-ya-yox--factcheck-695.)

73.  “Ad Hoc Report,” The Human Rights Defender of Armenia.

74. Armenian Legal Center for Justice & Human Rights. “Armenian Legal Center for Justice & Human Rights announces legal action before the European Court for POWs murdered by Azerbaijan.”

75. “Azerbaijan’s Prosecutor General’s Office Informs on Video Footage of Servicemen Circulating in Social Media,” Trend.Az, October 2, 2022, https://en.trend.az/azerbaijan/politics/3651816.html.

76. U.S. Department of State, Bureau Of Democracy, Human Rights, and Labor. 2021. “2021 Country Reports on Human Rights Practices: Azerbaijan.” state.gov. https://www.state.gov/wp-content/uploads/2023/03/415610_AZERBAIJAN-2022-HUMAN-RIGHTS-REPORT.pdf.

77. “ECHR Has Delivered a Decision,” Office of the Representative on International Legal Matters, September 30, 2020, https://rilm.am/en/events-en/echr-has-delivered-a-decision/.

78. Siranush Ghazanchyan, “European Court Indicates Interim Measures to Azerbaijan,” Public Radio of Armenia (blog), accessed December 16, 2023, https://en.armradio.am/2023/09/22/european-court-indicates-interim-measures-to-azerbaijan/.

79. Application of the International Convention on the Elimination of All Forms of Racial Discrimination (Armenia v. Azerbaijan), Provisional Measures, Order of 7 December 2021, I.C.J. Reports 2021, p. 361. https://www.icj-cij.org/sites/default/files/case-related/180/180-20211207-ORD-01-00-EN.pdf [henceforth I.C.J. Order of 7 December 2021], citing United Nations Office of the High Commissioner for Human Rights, "Nagorno-Karabakh: Captives Must Be Released – UN experts," news release, February 1, 2021, para. 87. https://www.ohchr.org/en/press-releases/2021/02/nagorno-karabakh-captives-must-be-released-un-experts.

80. I.C.J. Order of 7 December 2021

81. Armenian Legal Center for Justice & Human Rights, “Armenian Legal Center for Justice & Human Rights Announces Legal Action before the European Court for POWs Murdered by Azerbaijan,” The Armenian Weekly, August 10, 2021, https://armenianweekly.com/2021/08/10/armenian-legal-center-for-justice-human-rights-announces-legal-action-before-the-european-court-for-pows-murdered-by-azerbaijan/.

82. European Court of Human Rights. “Azerbaijan - Press Country Profile.” Last updated December 23, 2023. https://www.echr.coe.int/documents/d/echr/cp_azerbaijan_eng.

83. The United Nations. 2023. “Karabakh: Azerbaijan must 'guarantee the rights of ethnic Armenians.'” UN News. https://news.un.org/en/story/2023/09/1141577.

84. European Parliament. 2023. “JOINT MOTION FOR A RESOLUTION.” European Parliament. https://www.europarl.europa.eu/doceo/document/RC-9-2023-0393_EN.pdf.