# Case (Conditions and review of detention). Spivak v Ukraine 21180/15 \[2025\] ECHR 136

**URL:** <https://forum.mentalhealthlaw.co.uk/t/case-conditions-and-review-of-detention-spivak-v-ukraine-21180-15-2025-echr-136/3748>\
**Category:** MHLO updates\
**Created:** [12 June 2025 13:52 UTC](https://forum.mentalhealthlaw.co.uk/t/case-conditions-and-review-of-detention-spivak-v-ukraine-21180-15-2025-echr-136/3748 "2025-06-12T13:52:00Z")\
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**Author:** ![MHLO](https://forum.mentalhealthlaw.co.uk/user_avatar/forum.mentalhealthlaw.co.uk/mhlo/32/24_2.png) [@MHLO](https://forum.mentalhealthlaw.co.uk/u/MHLO)\
**Post date:** [12 June 2025 13:52 UTC](https://forum.mentalhealthlaw.co.uk/t/case-conditions-and-review-of-detention-spivak-v-ukraine-21180-15-2025-echr-136/3748/1 "2025-06-12T13:52:00Z")

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— Breaches of Article 3 and Article 5 arising from psychiatric detention. This extract shows how much better oral hearings in hospital are in principle compared with court or paper-based hearings held elsewhere: "The applicant did not attend any of the court hearings; each time he signed a pre-typed request for the case to be considered in his absence. According to him, he - like other patients - had been forbidden by the Dnipro hospital administration to attend the court hearings and had been forced to sign waivers of his right to participate."

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Full details available at: [https://www.mentalhealthlaw.co.uk/Spivak\_v\_Ukraine\_21180/15\_(2025)\_ECHR\_136?id=120625-1352](https://www.mentalhealthlaw.co.uk/Spivak_v_Ukraine_21180/15_(2025)_ECHR_136?id=120625-1352)