Meanwhile, on 5 January 2016 the European Court of Human Rights ruled in the case of Frumkin v. Russia (application no. 74568/12) that Mr Frumkin, a participant in the political rally at Bolotnaya Square in Moscow on 6 May 2012 held to protest against “abuses and falsifications” in the elections to the State Duma and the presidential elections, had been the victim of violations of Article 11 (freedom of assembly and association) both on account of the authorities’ failure to ensure the peaceful conduct of the assembly and on account of Mr Frumkin’s arrest, pre-trial detention and administrative sentence; a violation of Article 5 § 1 (right to liberty and security); and a violation of Article 6 §§ 1 and 3 (d). As reported, the Court found in particular that "the authorities had not complied with the minimum requirements in their duty to communicate with the leaders of the rally, which had been an essential part of their obligation to ensure the peaceful conduct of the assembly, to prevent disorder and to secure the safety of all citizens involved. Mr Frumkin’s arrest, detention and administrative conviction had been grossly disproportionate to the aims pursued; those measures must have had the effect of discouraging him and others from participating in protest rallies or more generally from engaging actively in opposition politics."