Summary
- The ECHR found that the full strip-search of photojournalist Kalliopi Melliou at Athens police headquarters amounted to degrading treatment and violated Article 3.
- Melliou had not been arrested and had been taken in for identification, while the Court found that the strict necessity of the measure had not been demonstrated.
- The case sits within a broader record of complaints by the Greek photojournalists' union concerning violence, intimidation, chemical agents, checks and obstruction of press photographers.
- The Court awarded €10,000 for non-pecuniary damage and €875 for costs and expenses.
The European Court of Human Rights condemned Greece over the full strip-search of photojournalist Kalliopi “Popi” Melliou at Athens police headquarters in 2013, unanimously finding that her treatment violated Article 3 of the European Convention on Human Rights.
The judgment in Melliou v. Greece (application no. 15807/19), delivered on September 22, 2026, matters not only because of what Melliou herself endured, but because it adds to a long record of complaints concerning the treatment of photojournalists by police in Greece.
What happened to Kalliopi Melliou
On February 27, 2013, in Exarcheia, Melliou saw four DELTA Team police officers and wrote down the license plate numbers of their motorcycles, believing that a violent incident or arbitrary police action might have taken place.
The officers stopped her and asked for identification. Melliou first asked to see their police credentials and was then taken to the Attica General Police Directorate for identification purposes. She had not been arrested and had not been charged.
At the police headquarters, her mobile phone was temporarily taken away, she was asked to hand over the note containing the plate numbers, and a body search was ordered. A female police officer instructed her to remove all her clothes, including her underwear, and conducted a full visual strip-search.
The ECHR: strict necessity was not demonstrated
The Greek Government argued that there had been serious suspicions of possible preparation of a terrorist act and that the search was required for security reasons. The ECHR was not convinced that a sufficient link had been established between the full strip-search and the prevention of crime or disorder.
The Court attached particular importance to the fact that Melliou had only been brought in for identification and had not been arrested or formally detained. It also noted that less intrusive alternatives such as a pat-down, body scanner or metal detector did not appear to have been considered first.
Her lawyer was kept away
The ECHR also considered the fact that Melliou’s lawyer was not allowed to accompany her to the area where she was questioned and searched. She met him only after the procedure was over and she was allowed to leave.
The Court found that this isolation was capable of intensifying the fear, anguish and sense of inferiority caused by the procedure.
This was not an isolated incident
Treating the case as a one-off episode from 2013 would ignore a wider pattern of complaints. The Union of Press Photographers of Greece has repeatedly reported violence, intimidation, chemical agents, arrests, restrictions on photography and disregard for professional press credentials.
In 2023, during a meeting with the leadership of the Ministry of Citizen Protection, the union submitted documents concerning what it described as unlawful actions by police forces against photojournalists, including incidents that had caused serious injuries and long-term health problems.
Further complaints followed in 2024 and 2025, including allegations of excessive police violence against photojournalists covering protests. In February 2026, the union again denounced bag searches, body searches and threatened transfers of photojournalists approaching Syntagma Square to cover demonstrations, even after they had shown professional credentials.
When cameras record those in power
Photojournalists are not present at demonstrations or police operations as spectators. Their work is to record what happens, often under difficult conditions and in places where visual evidence is essential to public information and accountability.
That is why violence, obstruction, detention or degrading treatment directed at photojournalists while they are documenting police action deserves the highest level of scrutiny. The ability of the press to record public authorities without fear is a basic requirement of democratic accountability.
The judgment and compensation
The ECHR unanimously concluded that the full strip-search amounted to degrading treatment and violated Article 3. Having found that violation, it considered it unnecessary to examine separately the complaint under Article 8 concerning private life.
The Court awarded Melliou €10,000 for non-pecuniary damage and €875 for costs and expenses.
What we think
Melliou’s case should not be reduced to another court story ending with a compensation figure. It concerns the degrading treatment of a photojournalist who was recording identifying details of police officers, and it took 13 years for a final judgment from Strasbourg.
More troubling is the fact that complaints concerning violence, chemical agents, checks, transfers and obstruction of photojournalists did not disappear in the years that followed. When the people documenting the actions of public authorities are themselves subjected to intimidation or violence, the issue goes beyond one profession: it affects society’s ability to see what is happening in public space.
PTTL has repeatedly criticised such incidents and will continue to do so. Photojournalists must be able to work without being treated as a problem simply because their cameras record what is happening.
Frequently asked questions
Was Kalliopi Melliou arrested?
No. According to the ECHR, she was taken to police headquarters for identification purposes and had not been arrested or formally detained.
What did the ECHR decide?
It unanimously found that the full strip-search had not been shown to be strictly necessary and amounted to degrading treatment in violation of Article 3.
How much compensation was awarded?
The Court awarded €10,000 for non-pecuniary damage and €875 for costs and expenses.
Have there been other complaints concerning police treatment of photojournalists in Greece?
Yes. The Union of Press Photographers of Greece has repeatedly documented and denounced incidents involving violence, chemical agents, searches, transfers and obstruction of photojournalists in recent years.
