131. Effective control.

The European Convention on Human Rights1 requires states parties to 'secure' the rights contained in the Convention to everyone within their jurisdiction2, pursuant to which the European Court of Human Rights has developed two additional conceptions of 'effective control': 'spatial control', which is concerned with circumstances where a state controls an area outside its national territory3; and 'personal control', which mostly involves state's agents taking a person into custody outside their territory