1. Introduction
Stalking is a serious social problem with dangerous implications for both social cohesion and political development. Despite the fact that as a phenomenon it is distinguished by generalized vagueness, it is indisputable that it has an intra-local and intertemporal character.
It is significant to note that as a behaviour it is found in the works of Hippocrates and Plutarch in antiquity and in those of Shakespeare later on. But even in modern times, it is projected in art[1]. In terms of the music industry, the Beatles’ “I want you” (1969), Police’s “Every Breath You Take” (1983), Coldplay’s “Shiver” (2000) and “Can’t Get You Out of My Head” (2001) by Kylie Minogue are worth mentioning. There are, also, many films that address the harassing and obsessive behaviours of stalkers and their impact on the lives of their victims. From “The Collector” (1965) and “Love Actually” (2003) to “Enduring Love” (2004) and “Obsessed” (2009). Finally, special mention must be made of the audiovisual production in Netflix’s “You” that was first released at the end of December 2019 and continues to pique the interest of subscribers. The series deals with the interpersonal relationships of a contemporary young man in the US, as well as the methods he uses to invade the lives of people who capture his attention.
In real life, few are unaware of the way John Lennon died in 1980, when in less than two years (1982) actress Theresa Sandana was stabbed outside her West Hollywood home by an undocumented migrant, who, previously, had hired a private investigator to detect her traces[2]. And while this was the case in the United States, in the United Kingdom stalking was first used as a term by the English press to describe cases of persecution of members of the royal family[3].
Historically, our society has only recently begun to perceive stalking as a criminal behaviour, as in the past it was primarily considered a sign of curiosity. Before 1990, in fact, it was not an illegal act and the abuser was brought to justice only if he/she was committing other criminally related acts at the same time[4].
The most socking fact for the public in the USA and the key point in dealing with stalking internationally was the death of the twenty-nine-year-old actress Rebecca Schaeffer in 1989 in Los Angeles. The victim was shot dead by Robert John Bardo. The obsessive fan visited her residence asking for an autograph. Having fulfilling his wish, she begged him to leave her house. The perpetrator, indeed, left but returned a little later to kill her.
This incident was the reason why in 1990 the State of California was the first legal order in the world to enact an Anti-Stalking Law[5]. Soon, the rest of the US legal order followed its example, both on state and federal levels, but also in European countries and Australia.
2. Definition – A more specific approach to the phenomenon
Despite the fact that stalking as a phenomenon runs through the entire body of social formation since ancient times, only in recent decades has it drawn the attention of the state[6]. Although the local legal orders have introduced legal grids to address the latter, its definition has proved to be particularly difficult in the context of dynamic social processes of which it is an integral part[7]. Precisely the main obstacle in this endeavor is that stalking, as a matter of fact, consists of certain acts that would be judged as socially and morally acceptable under different circumstances[8].
According to Logan and Walker, stalking “is understood as an intense and pursuit-oriented behaviour that is a pattern of repeated, intrusive actions — such as following, harassing, and threatening — that cause fear and distress in victims.”[9]. There is also the approach according to which this specific behaviour is defined as “a pattern of repeated and unwanted attention, harassment, contact, or any other course of conduct towards a specific person that would reasonably cause the sentiment of fear.”[10]. In other words, it is a repetitive, intense and unwanted communication that unfolds in various ways[11], such as phone calls, sending messages, e-mails, letters, gifts, property damage, spreading false news, tracking down the victim or even his/ her beloved ones and through any other suitable form of action for the stalker[12].
Stalking seems to be gender oriented. 70% of abusers are men and 80% of victims are women, as the behaviour is more common among people of the opposite sex[13]. According to a survey conducted by the US CDC in 2018 in the USA, the percentage of women who, at some point in their lives, became stalking victims reaches 16%, while that of the male population does not exceed 6%[14]. In Australia, one in five women[15] and one in twelve men experience stalking and obsessive stalking behaviour, while the corresponding statistics in the UK range from one in five to one in eighteen respectively[16].
In an effort to gain a more profound and substantial understanding of the critical social pathogenesis, it is worth noting that according to a recent survey conducted in the US in 2019, members of minorities due to their sexual orientation are the most exposed to stalking with a victim rate approaching 36%, while the corresponding statistics for heterosexuals is 15%[17]. Dealing with stalking among bisexuals is exacerbated as they are considered to be unstable and unfaithful — predominantly found among women, because, one the one hand, the sexual preferences of bisexual men are not always obvious, and on the other, because the latter often do not express their fear of stalking and consequently never record the corresponding incident of violence[18].
To the question of whether the culture and perceptions of the people involved are causally linked to stalking, the answer is yes. Data from a 2003 U.S. survey found that while 41% of Americans and 34% of Japanese students who participated believed they were stalking victims, only 11% of the former but 40% of the latter perceived the relevant behaviour as threatening. Thus, it was concluded that members of atom-centered Western societies interpret human contact differently than those who have lived in societies such as Japan[19].
Finally, it should be noted that the negative impact of stalking on the victims’ lives, in general, is so intense that some were diagnosed with post-traumatic stress, suicidal tendencies and depression after having experienced stalking behaviours[20], while other victims stated they would have preferred to have been physically abused, instead[21].
As for the stalkers, their motivation and actions are the two main points on which science focuses to illuminate the foggy landscape around the etiology of the underlying criminal behaviour.
Brian H. Spitzberg and William R. Cupach (2007) “identified eight groupings of stalking behaviours including: hyper-intimacy, mediated contacts, interactional contacts, surveillance, invasion, harassment and intimidation, coercion and threat, and aggression.”[22]. According to a different approach, however, stalking is divided into five categories[23]. The first is associated with rejected stalkers who, driven by feelings of reconciliation or even revenge, wish to maintain contact with people with whom they had a relationship in the past. Intimacy seekers, on the other hand, seek to develop bonds of love and devotion with people who have never been in their public surroundings. Another category is incompetent suitors who try to approach the person they are attracted to, in such a way, that they ultimately cause him/her fear and anxiety. Finally, it would be an omission not to mention the resentful stalkers who feel hurt and seek reciprocity of emotions and the predatory stalkers who enjoy the act of voyeurism and fantasies and are characterized by sadistic sexuality.
In conclusion, stalking is a dynamic condition that evolves within social reality and continues to pique the interest of the scientific community. It is of particular interest to stress that in the past it had been stated that the majority of stalkers were familiar with the victim itself[24]. However, according to recent research, the exact opposite has been proved[25]. It remains to be seen what new scientific data will come to light in the future regarding this criminal behaviour.
3. Cyberstalking
Cyberstalking could be defined as “repeated use of the Internet, email, or related digital electronic communication devices to annoy, alarm or threaten a specific individual or a group of individuals.”[26]. Behaviours that have been identified as partial manifestations of the above crime are actions such as monitoring the victim’s e-mail, sending e-mails, searching and finding personal information and monitoring posts on social media, as well as breaking passwords of online accounts[27].
We must admit that as law enforcement seeks to define stalking as a criminal act, the development of technology has given rise to a new class of stalkers who operate primarily on the internet and whose activity could easily be described as shifting sands for society and the state, as cyber staking is a constantly changing condition.
It is true that the Internet is a space that ensures invisibility and anonymity; it offers opportunities for deception and promotes freedom of expression, often exceeding the limits of impunity[28]. The situation became even more dangerous during the pandemic, as physical monitoring was not feasible, people were active mainly through the Internet, which contains large quantities of information, and therefore there was sufficient time for significant dangers to be developed in the infinitely vast digital world[29].
Although we do not have ample scientific data on cyberstalkers, according to a survey conducted in 2014, they can be divided into two categories[30]. The first includes those who use the Internet to directly communicate with their victim. These are usually former partners who seek to reinstate communication. Any failed attempt can lead to his/ her rage. Essentially, this is a more contemporary version of classic stalking that occurs mainly with physical monitoring.
The second category is related to people who do not want to communicate with the victim, but seek to offend and expose him/ her to the public of the digital era. For instance, they may publish photos from his/ her private life on social media or send e-mails with fake content on his/ her behalf. Frequently, in these cases, abusers are driven by anger and seek the victim’s attention or even revenge.
However, a study by Leroy McFarlane and Paul Bocij (2003) identified four major categories of cyberstalkers. According to the study, vindictive stalkers are the most dangerous because they are familiar with the tools of the Internet. Composites, on the other hand, are people who only seek to create negative emotions, fear and anxiety in their victim, unlike intimate cyberstalkers who wish to develop a bond and communication with the latter. Lastly, the fourth category is cyberstalkers who spy indiscreetly on more than two people at a time (collective)[31].
Given the above, it is worth of note that cyberstalking may be characterized by even more intense intervention, mainly because the perpetrator manages to make his/ her presence noticeable and establish control over the victim’s life[32]. The danger is even greater if one considers that the Internet is very compelling to underage users, for whose protection there are very few safety measures.
4. Cases with obsessive behaviours and their early jurisprudential approach
In our modern society, there are undoubtedly many challenges that stalking faces, which are being explored by the contemporary legal systems. Despite this, it has been recognized as a phenomenon of social pathogenesis since antiquity. In witness of the above, special reference should be made to two stalking cases that have been taken to trial by the English justice system in the distant past.
Case of Dennis v. Lane (1704)[33]
According to historical sources, Dr. Lane —a doctor by profession— strongly sought the companionship of Miss Dennis, disregarding the consent of her mother.
In fact, he did not hesitate to enter their home in order to violate the young girl’s private space. The two women, overwhelmed with the fear of the strange behaviour of Dr. Lane, fled to London in vain, as the obsessed admirer pursued them making every effort to be as close as possible. In fact, he was the attacker of many male figures who surrounded the social environment of Miss Dennis.
For the above reasons, he was brought before the court twice and finally sentenced to the payment of £400 to ensure peace in the relations between the two sides for a year and a day.
Case of Regina v. Dunn (1840)[34]
In this case, Richard Dunn spied on Angela Coutts for almost a year. In August 1838, the woman received two letters from her above admirer. That same month, she discovered she was being followed, which frightened her and forced her to seek new, temporary residence. He, however, located her and did not stop expressing his admiration for her in any way. In an effort to curb his actions, Coutts decided not only to always be accompanied by a male servant but to appeal to the authorities for assistance.
As a result, Dunn was temporarily detained at York Castle. However, the proceedings before the Court of Justice were not completed because the applicant had distanced herself from the alleged perpetrator and there was no apparent danger to her.
However, upon his release, he continued his obsessive activities, went on to London and approached the Coutts family home, terrorizing her. Although she resorted to the competent authorities to protect herself against her perpetrator, any attempt to avoid her admirer fell short. As such, she was always forced to leave the premises accompanied by an acquaintance and a male servant.
Finally, it is worthy to note that the last time the young woman sought legal assistance, the court rejected her request as Richard Dunn did not pose a real and significant threat to her life.
5. Council of Europe Convention on preventing and combating violence against women and domestic violence
The Council of Europe Convention on Preventing and Combating Violence against Women and Domestic Violence, signed on 11 May 2011, and which entered into force on 1 August 2014[35], is the first internationally binding legal text of its kind against the states that have ratified it.
It is clear from both the wording of the text in question and its explanatory report that it is based on three fundamental pillars. The first is associated with understanding the irreparable damage caused by gender-based violence to every aspect of our society and its cohesion. The other two are based on the dual need to protect the victims and the zero tolerance of the perpetrators and their criminal behaviour.
As far as the implementation of the provisions of the Convention is concerned, it has been signed by the vast majority of the member states of the Council of Europe (except for Azerbaijan and Russia)[36]. However, many countries have avoided its embracement so far.
The objections of some of them are quite remarkable. For instance, Hungary claims that its legal framework protects women’s rights and that the Council of Europe Convention on the Punishment of Gender-Based Violence promotes irregular migration indirectly[37].
Bulgaria avoids ratifying the current legal text on the pretext that its content is contradictory to the principles of Bulgarian society. Naturally, it would be an omission not to mention the case of Poland, which, while ratifying the Convention, does not implement the latter in practice. In fact, it intends to withdraw from it because —according to its competent authorities— women in the country are protected by the national legal framework in any case. Finally, it needs to be mentioned that Turkey recently —on 1 July 2021— withdrew from the Convention, causing a series of reactions both within and outside its borders[38].
Undoubtedly, the legal text under study is distinguished for its innovation and its key contribution to the fight against gender-based violence. One of the social phenomena it approaches is stalking, which according to article 34 thereof “Parties shall take the necessary legislative or other measures to ensure that the intentional conduct of repeatedly engaging in threatening behaviour towards another person, causing her or him to fear for her or his safety, is criminalized”.
In an attempt to showcase an interpretative approach to the aforementioned provision, the need for a thorough study of the explanatory report of the Convention is considered insurmountable in order to fill its interpretative gaps. After all, one would hardly dispute that article 34 does not fully —or at least adequately— render the content of the concept in question.
In light of the above, according to paragraphs 182-186 of the explanatory report of the Istanbul Convention, stalking is criminal behaviour, distinguished by its intensity and recurrence, the individual acts of which need not have a criminal dimension[39].
The perpetrator in this case, charged with the purpose of causing fear to his/ her victim, repeatedly and with characteristic intensity can be pushed into actions, as indicated in the text of the explanatory report, persistent physical or digital monitoring, causing damage to foreign property and spreading fake news.
At this point it is significant to emphasize that although the legal text in question is relevant to the acts of the alleged perpetrator vis-à-vis to his/ her victim, the Convention gives the parties, by ratifying the latter, the possibility of extending the scope of protection to the victim’s relatives and friends.
Based on article 78 § 3 of the Convention —and in accordance with paragraph 186 of its explanatory report— any State or the European Union may refuse to apply the criminal penalties of the legal text under consideration if they have adopted a non-criminal legal framework for an effective, proportionate and dissuasive management for the continuation of stalking.
In conclusion, it is true that the Istanbul Convention is gender oriented because women, as a result of their gender, are basically subjected to abusive behaviour and to acts of criminal proportions. This assumption, of course, does not necessarily mean that the contract is not intended to protect victims of different social profiles and characteristics, as the implementation or non-implementation of its regulatory framework is primarily based on the type of violence perpetrated against its victims. Ultimately, domestic violence and stalking in particular go beyond the narrow confines of social status.
6. The case law of the European Court of Human Rights (ECHR)
It is true that stalking, although as a social phenomenon is distinguished by the element of timelessness, began to interest modern legal orders quite recently. Consequently, we have not made any conclusions about its criminal dimension and the place of this criminal behaviour in our modern legal systems.
In view of the above, it appears from the ECHR rulings to date that the Strasbourg Court has not dealt extensively with the criminal activity in question. Presently, decisions relating to this criminally interesting conduct are limited to examining whether the State authorities acted within the scope of the law in each individual case, setting aside the facts which constitute the criminal act of stalking, as well as the legal status that frames it. Still, even when the ECHR was evaluated, albeit superficially, cases related to the issue at hand, were subject to parameters which added to its complexity. Nevertheless, according to the case law of the Strasbourg Court, the respective decisions are based by principle on the provisions of articles 2, 3, 5, 8 and 14 of the ECHR —as it will be seen from the following overview of the top (to date) and the most recent of the latter.
Osman v. United Kingdom – 23452/94 (Judgment 28.10.1998)
A case in point in the ECHR case law regarding stalking is undoubtedly Osman v. The United Kingdom (1998) relating to the obsession that teacher Paget Lewis had developed with his student, Ahmed Osman.
After a series of suspicious and strange incidents, the principal of the school, where Osman attended and the perpetrator worked, informed the authorities. This initiative was followed by an expert’s evaluation of the above teacher. Although no major disorder was initially diagnosed, the findings were overturned after two more psychiatric examinations. In particular, the medical staff considered that Paget Lewis should be removed from the school environment – which meant that he was suspended while the investigation was ongoing.
This was followed by vandalism and damages to Osman’s house, which, although not attributed to a certain person, was considered to be the actions of the teacher mentioned. When the police managed to gather evidence and search for the alleged perpetrator of the above criminal behaviours, he had disappeared.
A few months later, he returned to the Osman family neighborhood and, unnoticed by the British authorities, injured his student and killed his father.
According to the applicants, the police failed to curb the perpetrator’s obsessive disorder and therefore prevent the injury of the teenager, Ahmed Osman, and the loss of his father’s life.
This reasoning was basically based on the positive aspect of article 2 of ECHR, according to which the Authorities must make every effort to protect human life from any illegal activity. The violation of the above provision is investigated with the criterion of whether the competent bodies knew or should have known that the life of a person was in danger at the time they had to intervene[40].
The court (majority) ruled that from what was known to the authorities, the perpetrator did not intend to commit the criminal acts which, in the end, he committed[41]. Furthermore, given the presumption of innocence and the procedural guarantees that cover the entire criminal proceedings, it was not possible to prosecute him[42]. Finally, it was pointed out that the Osman family could also seek civil assistance (precautionary measures in criminal proceedings) as another deterrent measure to the realization of the perpetrator’s ideas — to which they did not resort. Consequently, the present action was dismissed.
However, it would be an important omission not to mention that following the same line of reasoning (Osman Test — as consolidated after the case cited here), there were a minority of judges who considered that the authorities should and could have prevented the criminal outcome, as the evidence at their disposal showed his escalating behaviour.
Volodina v. Russia – 41261/17 (Judgment 08.01.2018)
In Volodina v. Russia (2018), the Strasbourg Court ruled that Articles 3 and 14 of the ECHR had in fact been infringed.
According to the history, in 2014 the applicant entered into a relationship and lived with her particularly aggressive and violent partner in the city of Ulyanovsk, Russia.
In an attempt to escape the physical and psychological violence he inflicted on her on a regular basis, in May 2015 she moved to Moscow, carefully hiding her identity. However, he managed to deceive and kidnap her and remove her personal belongings in order to force her to return to their common home.
Although the police were informed about the abovementioned, in the end it was judged that there were no reasons for further escalation of the incident.
A few months later, and having previously been forced to return to her abusive environment, the applicant decided to return to Moscow in order to escape her partner — something she ultimately failed to do.
There were incidents of physical violence that took place in public places in the Russian capital, while it was revealed that the abuser had caused significant damage to her car, had placed a GPS device on her personal belongings, systematically spied on her, uploaded her private photographs on the internet and called her in order to threaten her and cause her to fear for her life. Finally, unable to find another way to deal with the situation in which she had found herself, in August 2018 the young woman decided to change her name and erase all traces of her existence and disappear.
It would be an omission not to emphasize that the woman regularly informed the police authorities as to what was happening and asked for their help, without ever being offered assistance under the pretext of the abuser’s relationship with the victim.
The above formed the basis on which the judgment was based in order to justify the applicant. In fact, the opinion of Judge Pinto De Albuquerque was considered important, claiming in cases of domestic violence, it is not accurate to adopt the Osman Test. This perspective is based on the nature and characteristics of the crimes committed in the context of violence within a family or partner, but also on the profile of the persons involved. Furthermore, according to judge Pinto De Albuquerque, cases such as the one under consideration must be approached separately with the basic criterion of the social phenomenon of gender-based violence, which is not limited to physical abuse. On the contrary, it also includes the psychological aspect of the latter[43].
The above procedure was followed by a second appeal of Volodina (2021)[44], according to which Russia violated Article 8 of ECHR as the authorities failed to protect her from the unscrupulous and criminal behaviour of her former partner.
In other words, according to her allegations, while the perpetrator was uploading —against her will— photographs of her personal life on the internet, creating fake profiles on social media, watching her by various means and blatantly trampling on her privacy sphere, the competent bodies systematically failed to prevent him from carrying out his plans. The lack of a thorough investigation and the slow process of obtaining information about the case in question inevitably led to the impunity of her former partner.
All the allegations were finally approved by the ECHR, which accepted that the handling of this case by the Russian authorities demonstrated the circumvention of Article 8 of the ECHR.
Tkhelidze v. Georgia – 33056/2017 (Judgment 08.07.2021)
In Tkhelidze v. Georgia (2021), the applicant’s daughter had moved with her six-year-old daughter into the apartment of her partner and his parents in Rustavi, Georgia. From the beginning of their cohabitation, he had aggressive outbursts, was possessed by pathological jealousy and used intermittent violence systematically.
The police was aware of the above, as both the victim and the perpetrator’s parents resorted to the authorities in order to bring peace to their relationship.
At the end of September 2014, no longer enduring the abusive behaviour of her partner, the applicant’s daughter decided to move away from him and moved to her mother’s residence with her minor child.
Since then, her life had become unbearable, because her former partner disturbed her family’s security and personal peace on a daily basis and cultivated a feeling of terror. In particular, he sent her menacing messages, made threats and spied on the house where she lived and her workplace. In fact, he did not hesitate to attempt a breach and enter her home illegally.
Despite repeated visits of the victim and her mother to the authorities, the police never initiated a process to protect or even investigate their allegations.
On 17 October 2014, the perpetrator finally went to his former partner’s workplace, asking her to have a private conversation at that time. Overwhelmed with fear, she did not refuse. In the ensuing meeting that occurred, the abuser shot and killed the young woman and then committed suicide.
The mother of the victim placed responsibility for the oligarchy on those who were responsible for preventing the perpetrator mentioned here from committing various crimes against his former partner. However, every effort fell short. Consequently, she finally resorted to the ECHR, claiming that Articles 2 and 14 of the ECHR were circumvented in light of the above facts.
The Strasbourg Court found that those provisions had been infringed. To illustrate, the relevant decision states that the two women sought help from the competent bodies at least eleven times and the abuser’s violent outbursts were a well-established condition which the authorities were well aware of not only because of the victim’s calls for help but also due to the fact that he was known to the police for offenses involving the consumption of alcohol and drugs. Finally, it was accepted by the Court that the authorities systematically downplayed the incidents of violence, they did not inform the victim of the options and legal avenues she could pursue to defend her rights, they showed unprecedented negligence and failed to attribute responsibilities for the inefficient handling of this incident.
7. Conclusion
Despite the interdisciplinary approach to stalking, the answer to its conceptual understanding remains perplex. Now, following the global and national social developments, perhaps the time has come for the state to address the multitude of issues that arise from this phenomenon, which are at the same time a social reality and an integral part of the mostly invisible crime. What is important is to realize that stalking is a complex condition with a variety of social, economic, cultural and ideological implications.
In this context, there is no doubt that the state and the scientific community must systematically address every aspect of this criminal act. In particular, taking into account that in this case the victims have to act to prove their abuse (taking photos, printing conversations on social media or in their e-mail, delivering letters to the authorities, etc.), new ways of informing and raising public awareness must be found. Targeted training of police and judicial authorities is considered necessary, so that the victims can be supported and a climate of trust and a sense of security should be cultivated. Finally, it should be pointed out that the detailed and complete data recording and the systematic statistical recording of stalking are extremely important tools of research and theory, as they will make a decisive contribution to a better understanding and treatment of the phenomenon.
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[31] M. D. Smith (Ed.), op. cit., pp. 383-384.
[32] D. Woodlock, 23(5) Violence Against Women (2017) 592, DOI: 10.1177/1077801216646277.
[33] P. Mullen/ M. Pathé/ R. Purcell, op. cit., p. 283.
[34] P. Mullen/ M. Pathé/ R. Purcell, op. cit., pp. 283-284.
[35]https://www.coe.int/en/web/conventions/full-list?module=treaty-detail&treatynum=210, last viewing on 17.11.2021.
[36] https://www.coe.int/en/web/conventions/full-list?module=signatures-by-treaty&treatynum=210, last viewing on 17.11.2021.
[37] https://www.europarl.europa.eu/doceo/document/E-9-2020-002981_EN.html, last viewing on 17.11.2021.
[38] https://www.coe.int/en/web/istanbul-convention/turkey, last viewing on 17.11.2021.
[39] https://rm.coe.int/1680a48903, last viewing on 17.11.2021.
[40] M. Galanou, ‘The article 2: The right to life’, in I. Sarmas/ K. Kontiadis/ C. Anthopoulos (Ed.), ECHR (ΕΣΔΑ) (Sakkoulas Publication, Athens-Thessaloniki, 2021), pp. 88-89.
[41] P. Jougleux, The civil liability of the state (Η αστική ευθύνη του Κράτους) (Sakkoulas Publication, Athens-Thessaloniki, 2012), p. 51.
[42] T. Zolotas, The protective function of individual rights according to the case law of the ECtHR (Η προστατευτική λειτουργία των ατομικών δικαιωμάτων κατά τη νομολογία του ΕΔΔΑ) (Sakkoulas Publication, Athens-Thessaloniki, 2018), pp. 123-124.
[43] R. J. A. McQuigg, ‘The European Court of Human Rights and Domestic Violence: Volodina v. Russia’, 10 International Human Rights Law Review (2021) 163.
[44] Application Number 40419/2019.
