of Court titled ‘Just satisfaction claims’ 1367 (hereinafter also referred to also as ‘the Directions on just satisfaction’). The Directions on just satisfaction regulate the formal requirements to claims, defines the term ‘damage’ and set forth types of damage and forms of the Court’s awards. A summary of information regarding compensation granted in the form of equitable relief may also be found in the Memorandum on monitoring of the payment of sums awarded by way of just satisfaction 1368 elaborated by the Department for the Execution. The Memorandum regulates the issues of determining the beneficiary, circumstances in which it is necessary to obtain a power of attorney, place of payment, limits of payment and the currency used. In addition to primary sources, we can find specific conditions for determining the award of just satisfaction and the grounds in the case-law of the Court. It can be said that in its judgments, the Court addresses the issue of just satisfaction to such an extent that this practice may serve as a good source for the detailed examination of the notion. 1369 Moreover, some of the judgments of the Court deal directly with the issue of just satisfaction under Article 41 of the Convention, after a separate judgment on merits. 1370 Now, the Court even includes the expression ‘just satisfaction’ in the title of cases. 1371 Before significant reform of the Convention in 1998, 1372 just satisfaction was envisaged by Article 50 of the Convention; therefore, earlier judgments had this provision in the title. 1373 The new edition entered into force on 1 January 2014, p. 63. URL: accessed 20 July 2015. 1367 Practice Directions on Just satisfaction claims. Rules of Court incorporates amendments to Rule 47 made by the Plenary Court on 6 May 2013. The new edition entered into force on 1 January 2014, p. 63. URL: accessed 20 July 2015. 1368 Monitoring of the payment of sums awarded by way of just satisfaction: an overview of the Committee of Ministers’ present practice. Memorandum prepared by the Department for the Execution of Judgments of the European Court of Human Rights (DG-HL). No. CM/Inf/DH(2008)7 final of 15 January 2009. URL: accessed 20 July 2015. 1369 ICHIM, 2014, cited above. 1370 Belvedere Alberghiera S.r.l. v. Italy (just satisfaction), no. 31524/96, 30 October 2003; Dacia S.R.L. (just satisfaction), cited above; EugeniaMichaelidouDevelopments Ltd andMichael Tymvios (just satisfaction friendly settlement), cited above; Forminster Enterprises Limited v. the Czech Republic (just satisfaction), no. 38238/04, 10 March 2011; Holy Synod of the Bulgarian Orthodox Church (Metropolitan Inokentiy) and Others v. Bulgaria (just satisfaction), nos. 412/03 and 35677/04, 16 September 2010; Oferta Plus SRL v. Moldova (just satisfaction), no. 14385/04, 12 February 2008; Rock Ruby Hotels Ltd v. Turkey (just satisfaction), no. 46159/99, 26 October 2010 and Megadat.com SRL v. Moldova (just satisfaction – striking out), no. 21151/04, ECHR 2011. 1371 Agrokompleks v. Ukraine (just satisfaction) , no. 23465/03, 25 July 2013; Agurdino S.R.L. v. the Republic of Moldova (just satisfaction), no. 7359/06, 29 October 2013; Immobiliare Cerro S.A.S. v. Italy (just satisfaction), no. 35638/03, 5 June 2012; Immobiliare Podere Trieste S.r.l. v. Italy (just satisfaction), no. 19041/04, 23 October 2012 and Rodinná záložna, spořitelní a úvěrní družstvo and Others v. the Czech Republic (just satisfaction), no. 74152/01, 19 January 2012. 1372 The reform was introduced by Protocol No. 11 to the Convention of 11 May 1994. On 1 November 1998 the Protocol gained entry into force. URL: accessed 20 July 2015. 1373 Pine Valley Developments Ltd and Others v. Ireland (Article 50), 9 February 1993, Series a no. 246-B; Pressos Compania Naviera S.A. and Others v. Belgium (Article 50), 3 July 1997, Reports of Judgments and Decisions 1997-IV; The Holy Monasteries v. Greece (Article 50), 1 September 1997, Reports of
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