Cyberviolence Against Women Under International Human Rights Law: Buturugă v Romania and Volodina v Russia (No 2).

This article examines the European Court of Human Rights' (Court) recent judgments in Buturugă v Romania and Volodina v Russia (No 2), which mark the Court's first recognition of cyberviolence against women as a violation of Article 8 of the European Convention on Human Rights (ECHR). While these rulings advance the mainstreaming of cyberviolence within international human rights law by imposing binding state obligations to prevent, protect from, and punish such violence, the article critiques the Court's reliance on Article 8—a qualified right subject to lawful state interference—rather than Article 3, which prohibits torture and inhuman or degrading treatment and is absolute. The article argues that framing cyberviolence under Article 8 inadequately reflects the gravity of the harm, risks undermining progress in recognizing violence against women as a severe human rights violation, and fails to fully address the evolving public/private distinction in the digital era that complicates state responsibility. It concludes that future Court analyses would benefit from applying Article 3 to better capture the severity of cyberviolence against women and to reinforce states' non-derogable obligations in this context.