legality cannot be interpreted broadly, since [any deprivation of liberty constitutes an] exception to the fundamental guarantees of personal freedom (RCC Decision, p. 12). The lack of clarity of the immigration law concerning the detention of foreign nationals whom it was impossible to remove from Russia meant that the domestic legislation did not meet the criteria set by the Convention. In this context, the RCC also made explicit references to the ECtHR jurisprudence against Russia, and the general measures specified in another case of a stateless person sentenced to administrative removal – Mr Roman Anatolyevich Kim, a former USSR citizen born in Uzbekistan. In Kim v Russia, (application no. 44260/13, judgment 17 July 2014) the Strasbourg Court obliged the Russian Federation to ‘secure in its domestic legal order, a mechanism which allows individuals to initiate proceedings for the examination of the lawfulness of the detention pending removal’ (para 71, Kim v Russia). Given the two-year length of the detention, deemed by ECtHR as unreasonable, the Kim v Russia judgment also obliged Russia take ‘the necessary general measures to limit detention periods so that they remain connected to the ground of detention applicable in an immigration context’ (para 72, Kim v Russia). The RCC, by referring to this judgment, affirmed the necessity of these general measures in the domestic context and provided an additional important stimulus from within the domestic legal system for the Russian Duma to introduce specific legislation. Until this new law is in place, the RCC put forward an interim measure, whereby stateless persons placed in detention pending administrative removal should be granted the right to appeal to court to review the legality of their further detention ‘either where there is no evidence of actual possibility of their deportation, or after three months from the date of the imposition of administrative penalty’ (RCC Decision p. 27). The RCC went even further and suggested that the legislator creates ‘a special migratory status for stateless persons in 12