A recent decision by the Cypriot Court of Appeal to order the extradition of Mikhail Ignatkin to Russia highlights a divergence from English and European human rights jurisprudence. Clients of Russian origin who may face prosecution at home should be cautioned against settling in Cyprus. Those who hold Russian investments through Cypriot structures, many of them administered or advised from London, should also consider whether Russian proceedings could follow them there. Until the Cypriot courts align with the approach taken in England and in Strasbourg, Cyprus cannot be assumed to offer the protection that English courts have consistently afforded.
The Court of Appeal’s decision to extradite Ignatkin runs counter to English practice and sits uneasily with Strasbourg case law. Ignatkin, a decision-maker at a state-funded space company, is accused of helping a contractor win a contract without a proper tender at an inflated price, resulting in the diversion of RUB 840 million (approximately €7.8 million). He was arrested in Cyprus in November 2024.
Background to the Case
The Paphos District Court initially refused extradition on 25 November 2025, citing concerns about the validity of the Russian detention order and the reliability of Russia’s assurances. The court was not satisfied that the Russian detention order of December 2020 remained in force, as required by Article 12 of the European Convention on Extradition.
The Attorney General appealed the decision, and the Court of Appeal adopted a “liberal interpretation” of the treaty, holding that the order had not lapsed. They dismissed a cross-appeal alleging that Russia had breached its duty of candour over material on proceedings against alleged accomplices.
Implications of the Decision
The individual-risk test applied by the Cypriot courts is hard to reconcile with the European Court of Human Rights’ (ECtHR) decision in Liu v Poland, which held that an applicant who would be placed in a detention system carrying a general real risk is “relieved from showing specific personal grounds of fear”.
In practice, this development means that individuals like Ignatkin, who are wanted by the Russian authorities, may face a higher risk of extradition from Cyprus. The Committee for the Prevention of Torture (CPT) reported in November 2024 that Russia was refusing to cooperate ahead of Russia’s withdrawal from the European Convention for the Prevention of Torture due to take effect on 1 November 2026.
The Paphos court also faulted Ignatkin for producing no evidence about the specific facility in which he would be held, although Ananyev v Russia had already found a structural problem in Russian remand detention. Neither Cypriot court cited Liu.
