Denmark has been condemned by the European Court of Human Rights (ECHR) over the prolonged use of restraint belts in psychiatry, after a young man was unlawfully kept restrained for more than 11 days in 2016. The ruling, delivered on 31 March in Makki v. Denmark, found that the treatment violated Article 3 of the European Convention on Human Rights, which prohibits inhuman or degrading treatment.
What Makki v. Denmark says about prolonged restraint belts
The case concerns Abdeelhadi Abbas Makki, a Danish man with paranoid schizophrenia who was involuntarily admitted to psychiatric care on 3 June 2016. After he attacked a nurse with a fork the same day, he was placed in belt restraints. The measure continued until 16 June, when he was transferred to a more secure psychiatric ward.
Danish authorities had already acknowledged that the restraint was unlawful from 5 June at 09:30 onwards, following a decision by the Psychiatric Patient Complaints Board. That meant the man had been unlawfully restrained for 11 days, 10 hours and 48 minutes.
The Strasbourg court concluded that the intervention lasted longer than what was strictly necessary. It accepted that the patient posed a serious risk, but found that the prolongation of the restraint was not justified in a way consistent with Article 3 safeguards and with the requirement that coercive measures remain a last resort.
Why the ruling matters beyond this Danish case
According to Denmark’s Institute for Human Rights, this is the longest case of belt restraint that the European Court of Human Rights has examined so far. The previous longest case considered by the court was Lavorgna v. Italy in 2024, which involved eight days of restraint.
The court ordered Denmark to pay the applicant 20,000 euros in compensation. The case adds to a growing body of Strasbourg rulings and settlements concerning the use of coercive measures in psychiatric care, especially where prolonged restraint is involved.
Belt restraints are still widely used in Danish psychiatry
The ruling also draws renewed attention to the broader use of coercion in Denmark’s mental health system. According to the 2024 annual report by the Task Force for the Prevention of Coercion in Psychiatry, there were 3,855 cases of belt restraint involving adults in Denmark in 2024, with an average duration of around 17 hours.
That average is far below the duration examined in this case. Still, the figures show that belt restraint remains a common practice in Danish psychiatry, despite years of political attention and repeated efforts to reduce coercion.
The Ministry of the Interior and Health (Indenrigs- og Sundhedsministeriet) said after the ruling that rules and practices have changed since 2016, and that the Danish Health Authority continuously monitors the use of coercion in psychiatry. The ministry said it would now study the judgment closely to assess whether further measures are needed.
The judgment also lands at a time when Denmark has set a stricter policy target. A 2025 mental health plan aims to cut coercion by 30% by 2030 and to limit the use of mechanical restraints to exceptional cases, with a maximum duration of four hours.
Earlier rulings had already put Denmark under pressure
This is not the first time Denmark has faced scrutiny over psychiatric restraints under Article 3. In Aggerholm v. Denmark in 2020, the European Court of Human Rights ruled against Denmark over a 23-hour belt restraint, finding that authorities had waited too long before reassessing whether the patient remained a danger to himself or others.
Danish courts have also dealt with even longer cases. In 2021, Denmark’s Supreme Court found that a nine-month belt restraint amounted to treatment contrary to the prohibition of torture and inhuman treatment.
The same applicant in the new Strasbourg case also has another pending case against Denmark, concerning his confinement to a room for three and a half years at the high-security psychiatric institution Sikringen.
What this could mean for Danish psychiatric policy
The new ruling is likely to intensify pressure on Danish authorities to show that restraint belts are used only as a last resort, for the shortest possible time, and under close review. It may also add momentum to ongoing debates in Denmark about how to reduce coercion in psychiatry while protecting staff and other patients.
Beyond Denmark, the judgment fits into a wider European discussion about the balance between safety, patient rights and the limits of coercive interventions in mental health care. In a Nordic and EU context that increasingly emphasises human rights oversight, the case is another reminder that psychiatric policy is also a question of legal safeguards and dignity.
