Alinea 105 Gerechtshof Amsterdam 19 juni 2025

142. In order to determine whether a person has been deprived of his or her liberty, the starting point must be his or her specific situation, and account must be taken of a whole range of criteria, such as the type, duration and effects of the measure in question and the manner in which it was implemented (see Khlaifia, cited above, § 64). The Court attaches importance to factors such as whether there is a possibility to leave the restricted area, the degree of supervision and control over the movements of the person concerned, the extent of that person’s isolation and the possibility of contact with the outside world (see Guzzardi, cited above § 95; Friedrich and Others; cited above, § 151; and H.M. v. Switzerland, no. 39187/98, § 45, ECHR 2002‑II).

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