The 1969 “Greek Case” in the Council of Europe: A Game Changer for Human Rights. By KostisKornetis, Victor FernándezSoriano, KristinaKjaersgaard, NicolasManitakis, AlexandrosNafpliotis, and AnnaPapaeti, editors. London, New York: Bloomsbury Academic, 2024. 312 pp. 39. 95 (paperback). ISBN: 978‐1‐35‐029657‐2

In 1967, Denmark, Norway, and Sweden, later joined by the Netherlands, brought a complaint against Greece before the Council of Europe. A coup in Athens had installed a junta of army colonels that suspended constitutional guarantees, detained thousands of political opponents, and used torture as an instrument of rule. Across Scandinavia, the coup provoked sharp reactions from parliamentarians, lawyers, and segments of the press. For governments that had invested the European Convention on Human Rights (ECHR) with legal and moral significance, the dramatic collapse of constitutional order in a fellow member state posed a clear challenge to Europe's postwar order. What became known as “the Greek Case” had important implications in elaborating the definition of torture, demonstrating the feasibility of an intra-state procedure for using the Convention to uphold standards across the system, and crystallizing a debate over whether membership in European bodies carries enforceable human rights conditions. The proceedings drew unusual public attention and culminated in Greece's withdrawal from the Council in 1969 rather than face expulsion. Legal scholar Ed Bates observed that the report on the case issued by the European Commission on Human Rights seems to mark the first time that an international human rights body concluded that a state had practiced torture (The Evolution of the European Convention on Human Rights 2010, 266). As The 1969 “Greek Case” in the Council of Europe makes clear, the investigation also helped consolidate evidentiary standards for proving torture, enhanced the emerging role of nongovernmental organizations like Amnesty International in documenting abuse, and signaled a shift away from noninterference in domestic affairs toward a more interventionist conception of international law. It also exposed a durable limit: neither the legal proceedings nor the surge of public outrage curbed the regime's reliance on torture (7, 125). Despite the Greek Case's significance, the surge of English-language human rights scholarship in recent decades has paid it little attention (though there is increasing interest from scholars writing in Greek). General histories of the junta and analyses of the ECHR system naturally mention it, and legal studies of the ECHR discuss it, but there is no comprehensive account of its political origins and implications. The broader neglect is partly a function of the case's anticlimactic trajectory, given that Greece withdrew from the Council before a final showdown. The failure to produce a clear outcome makes it hard to depict the case as a redemptive tale, the more so because the real power lay with NATO, where conditioning membership on observance of human rights standards was rejected outright. For historians, the interstate complaint does not fit neatly into a narrative that locates the decisive breakthrough of human rights in the NGO mobilizations of the 1970s. And the restoration of democracy in Greece in 1974 meant that there was no prolonged reckoning, as in Argentina and Chile, that sustained transnational campaigns for decades. Historians are attracted to dramatic turning points. The Greek Case expanded the capacity of the European human rights system in a slow, non-dramatic, procedural way. This new volume offers an important corrective, excavating many dimensions of a case that has not received the attention it merits. The book grew out of an international conference held in Athens in 2019, conceived by historian Kostis Kornetis. Co-organized by research institutes connected to the states that brought the case and supported by Denmark's Carlsberg Foundation, the conference aimed to reassess the historical and legal dimensions of the case and to connect past and present debates about torture and institutional accountability. Notably, torture survivors and former anti-junta activists were included in a scholarly conversation that more typically remains detached from lived experience. The organizers have made videos of the conference presentations available online (at https://www.youtube.com/@greekcase6671). The volume's scope is ambitious, combining discussions of international law, transnational activism, domestic politics, and evolving definitions of torture. It situates the Greek Case not only in the evolution of regional rights enforcement but in the wider history of Cold War politics and solidarity movements. The 21 contributors represent a wide range of disciplines and geographic expertise. They include historians of modern Europe and the Cold War, legal scholars specializing in the European Convention system, political scientists, and researchers of transnational activism, drawn from universities and research institutes across Scandinavia, Greece, Germany, Italy, Spain, the United Kingdom, and the United States. One contributor, James Becket, was a key protagonist in the events. The volume's structure builds logically, proceeding from the immediate diplomatic and legal origins of the interstate applications, through their reverberations across European political movements and solidarity networks, to their longer-term implications for torture jurisprudence and transnational activism. The opening section reconstructs the interstate applications themselves, examining Scandinavian and Dutch initiatives and the political calculations behind them. The second section traces the case's impact in West Germany, Italy, Spain, and the European Community. Subsequent chapters look at leading anti-junta figures in Greece, protest techniques, and the networks that smuggled witnesses to Strasbourg, France to testify before the Commission. The volume covers the role of Amnesty International and transnational solidarity campaigns before closing with a sustained engagement with torture that covers legal definitions, gendered dimensions, and lasting jurisprudential effects in Greek courts. The editors describe the book as offering a “meso-level” approach, bridging institutions (macro) and individual stories (micro), while interweaving accounts of state diplomacy, legal doctrine, international organizations, and grassroots activism. Inevitably in a multi-authored collection, certain themes repeat across chapters, but the volume presents a coherent arc, layering perspectives to build an integrated understanding of the national, international, and institutional dimensions of events. A recurring theme is the role of individuals, from figures such as West German Social Democratic leader Willy Brandt to the Greek actress and torture survivor Kitty Arseni, allowing the volume to spotlight contingency and the interplay of personality, principle, and political circumstance. Konstantina Maragkou's chapter on international campaigning offers an excellent overview for teaching purposes, compressing a complex web of actors into a lucid account of how human rights campaigns operated in practice. Though the volume does not offer a global story, it persuasively demonstrates the Greek Case's transformative role in Europe, particularly in shaping institutions and advocacy networks that influenced wider political and moral developments. The volume is framed in a celebratory mode. The editors liken the “large-scale” anti-junta mobilization to the international antifascist mobilization during the Spanish Civil War (6) – a heroizing analogy that significantly over-claims. The introduction mentions that the UK, West Germany, and France worked together to block Greece's expulsion from the Council, and Stan Draenos's contribution vividly details the Nixon administration's strong backing of the colonels' regime, but the forces arrayed against the pro-democracy movement and the security considerations that set a political ceiling on what the Council could do are mostly sidelined. The volume instead calls attention to the “game-changing” aspects of the case, situating it as “the missing link” between the Nuremberg Trials and the war crimes tribunals of the 1990s (7). The Greek Case is important to understanding how torture came to be defined and debated, and many chapters help explain why torture emerged as the paradigmatic human rights violation of the period. One especially interesting contribution is by Anna Papaeti, a researcher who writes on opera, the interplay of music, sound, and trauma, and the intersections of politics, ethics, and aesthetics. Her chapter depicts the Greek Case as a breakthrough in confronting psychological torture techniques, such as sound and sensory manipulation. But she also shows that it was a missed opportunity, since the Greek Case's broad conception of mental suffering was narrowed in the 1978 Ireland v. United Kingdom judgment about the “five techniques” used by the British against suspected IRA detainees. Papaeti's interdisciplinary approach, which combines trauma studies, sound studies, jurisprudence, and Cold War history, makes her piece one of the volume's most conceptually innovative contributions. The book ends with an interview with James Becket, who was a recent Harvard Law School graduate when the then-fledgling Amnesty International sent him to Greece to gather evidence from the junta's victims. Amnesty's reports on Greece and Becket's 1970 Barbarism in Greece helped establish reporting models for much of the activism of the 1970s. The papers of James and his late wife, Maria Becket Hari, who ran a network that supplied victims with forged passports (121), are now available at the University of Oxford's Bodleian Archives. Like this important, carefully conceived, and richly documented volume, they should spur renewed attention to a formative episode in the global history of human rights. The reviewer was a keynote speaker at the 2019 conference from which this collection was derived but did not participate in the volume.