Who is Yüksel Yalçınkaya?
Yüksel Yalçınkaya was a teacher in Kayseri who was dismissed in 2016 under Decree‑Law No 672. He received a 6 year 3 month prison sentence for terrorism based on alleged ByLock use, a Bank Asya account and membership of certain associations and unions. After exhausting domestic remedies he applied to the European Court of Human Rights, which found that several of his rights—including the right to a fair trial—had been violated. The judgment sets a precedent for thousands of similar cases in Turkey.
Importance of the ECtHR Judgment
The European Court of Human Rights held that the use of the ByLock application, having an account at Bank Asya and membership of certain associations or unions cannot, by themselves, constitute sufficient evidence of membership of a terrorist organisation, thereby establishing precedent‑setting case‑law.
The case concerns a breach of the principle of “no punishment without law” (Article 7) stemming from the applicant’s conviction for membership of an armed terrorist organisation based solely on alleged use of the encrypted messaging app “ByLock”, without an individualised assessment of the material and mental elements of the offence.
The case also involves a violation of the right to a fair trial (Article 6) because the domestic courts failed to give due consideration to the applicant’s arguments on the collection and processing of electronic evidence.
It further entails a violation of the freedom of assembly and association (Article 11) because the national courts unpredictably expanded the scope of the offence by relying on the applicant’s membership of a trade union and an association deemed linked to a terrorist organisation.
Under Article 46 the Court held that reopening the criminal proceedings—if requested—would be the most appropriate way to bring the violations to an end and to afford the applicant redress, and that the authorities must take suitable general measures to tackle the systemic problem arising from domestic courts’ approach to ByLock use.
The judgment could serve as a precedent for roughly 8,500 applications currently pending before the Court and potentially for up to 100,000 cases overall.
Turkey has submitted two separate action plans concerning the ECtHR’s Yüksel Yalçınkaya judgment.
The first action plan was submitted on 5 August 2024. The revised second plan was submitted in March 2025 and will be examined at the Committee of Ministers’ June 2025 session.
Concerning individual measures, the authorities have provided information on criminal cases reopened following the Court’s judgment.
As to general measures, the authorities have supplied information on domestic courts’ current practice concerning the relevant provisions of the Turkish Criminal Code and have submitted numerous examples of domestic judgments.
However, no concrete or effective steps have yet been taken to remedy the violations found by the Court, and the judgment has not been implemented in practice.
Article 6 Violation – Right to a Fair Trial
Violation of the right to a fair trial. The Court found the conviction to be contrary to the Convention because it was based on insufficient evidence and lacked a legal basis. The domestic courts did not properly consider the applicant’s arguments on the collection and handling of electronic evidence.
Article 7 Violation – No Punishment without Law
Violation of the principle of “no punishment without law”. The Court ruled that the use of ByLock and opening an account at Bank Asya cannot by themselves prove membership of a terrorist organisation. Convicting the applicant without an individualised assessment of the material and mental elements of the offence was contrary to the Convention.
Article 11 Violation – Freedom of Assembly and Association
Violation of the freedom of assembly and association. The Court considered it contrary to the Convention that Yalçınkaya’s membership of a trade union and an association deemed linked to a terrorist organisation was used to support his conviction, thereby unpredictably widening the scope of the offence.
Court Judgment and Related Documents
Action Plans Submitted by Turkey to the Committee of Ministers
Submissions Sent to the Committee of Ministers by Civil‑Society Organisations
Action Plan - March 2025
June 2025 Committee of Ministers (DH) Meeting
This document is the updated action plan submitted by Turkey in the context of the Yüksel Yalçınkaya v. Turkey case.
Action Plan - August 2024
September 2024 Committee of Ministers (DH) Meeting
This document is Turkey's first official action plan in response to the European Court of Human Rights' violation judgment dated 26 September 2023 in the case of Yüksel Yalçınkaya v. Turkey.
Justice Square Foundation, Italian Federation for Human Rights, Cross Border Jurists Association, The Arrested Lawyers Initiative, Solidarity with OTHERS, Human Rights Solidarity, Human Rights Defenders
March 2025 Committee of Ministers (DH) Meeting
Justice Square Foundation, Italian Federation for Human Rights, Cross Border Jurists Association, The Arrested Lawyers Initiative, Solidarity with OTHERS
December 2024 Committee of Ministers (DH) Meeting
Justice Square Foundation, Italian Federation for Human Rights, Cross Border Jurists Association, The Arrested Lawyers Initiative, Solidarity with OTHERS
September 2024 Committee of Ministers (DH) Meeting
Human Rights Solidarity, Arrested Lawyers Initiative, Italian Federation for Human Rights
September 2024 Committee of Ministers (DH) Meeting
Justice Square Foundation, Italian Federation for Human Rights, Statewatch, Cross Border Jurists Association, The Arrested Lawyers Initiative, Solidarity with OTHERS
September 2024 Committee of Ministers (DH) Meeting