The present threatening atmosphere for NGOs in Russia continues a multi-year trend of backtracking on democratic developments. The past five years have witnessed the progressive dismantling of all checks and balances on executive powerincluding the independent media, plurality of opinion in the national legislature and among regional governors, and the independence of the judiciary. Although President Vladimir Putin has consistently paid lip service to principles of democracy and human rightsand has repeatedly justified his steps to concentrate power in his hands as needed to create a more effective system of governmentRussia has gone back on many achievements of the 1990s.
Russias political structures may have been flawed and dysfunctional when Vladimir Putin came to power in late 1999, but public debate of policy issues, one of the great achievements of glasnost and a basic element of any democracy, was vigorous. In the State Duma (the lower chamber of parliament) political parties of different persuasions engaged in strident debate over issues ranging from foreign to agricultural policy. The electronic and print media, though dominated by oligarchs who used them as tools to promote their own interests, presented a wide variety of different opinions. Regional governors were a force to be reckoned with, and the courts had gained some degree of real independence from the executive. Finally, a quickly developing community of NGOs had started playing a role in policy making. During the past five years, President Vladimir Putins policies have systematically reversed achievements in each of these areas.
In September 2004, President Putin essentially blamed the collapse of the Soviet Union and the deficiencies of Russias transition to democracy for the hostage taking at a school in Beslan, North Ossetia, and the subsequent massacre of hundreds of children, parents, and teachers.4 He subsequently pushed through a package of political changes that have taken his already overwhelming dominance of Russian politics to a new level. President Putin now essentially appoints regional governors, rules for parliamentary elections have been changed in a way that is likely to further reduce opposition in parliament, and proposals that would give the executive branch more control over the judiciary are currently being considered by the State Duma.
In November 2004, Putin defended his post-Beslan proposals, saying that they aimed to create a system of organizing power that does not go against the principles of a democratic society and that is better able to solve the problems the country faces.5 Many Russia analysts, however, felt that the Kremlin opportunistically used the Beslan tragedy to push through political changes that it had long been considering. As Yevgenia Albats, a professor of political science at Moscows Higher School of Economics and a respected Kremlin critic, commented:
I believe that each and every political reform that has been announced during the past months had nothing, and has nothing, to do with Beslan. Beslan served as a pretext. The Kremlin just capitalized on the fear and anger that developed inside Russian society after the hostage crisis in Beslan and decided to use the time after the crisis to announce its reforms, [all with the objective] to reinstate full control over society.6
When Vladimir Putin took office in late 1999, several big media conglomerates owned by a number of oligarchs controlled Russias nationwide television channelsthe primary source of information for the vast majority of Russiansas well as many of its radio stations, newspapers, and Internet publications. Although the agendas of these oligarchs heavily influenced the news coverage in these media, Russians did get to see a wide variety of opinions on their television screens and in their newspapers; the oligarchs used their media to battle each other and the government.
In what he would later call the liberation of news outlets from oligarch censorship,7 President Putin aggressively started seeking editorial control over the media, in particular national television channels, after he took office. By mid-2003, all television stations with national reach had been placed under the firm control of the Kremlin, as had most radio stations. Television news had become monotone, perpetually portraying the president in a positive light and avoiding criticism of his policies. All programs featuring live debate on political issues had been cut. Only a small number of newspapers and Internet publications provided some plurality of opinion, but their readership was marginal.
The crackdown on the media started in 1999 with restrictions imposed on journalists covering the renewed hostilities in Chechnya. Acutely aware of the fact that critical media coverage and an increasingly skeptical public had contributed to forcing the Russian government to negotiate a retreat from Chechnya in 1996, the administration moved to restrict journalists access to and reporting on the conflict zone.8 Journalists were only allowed into Chechnya by joining official tours organized by the Russian authorities and escorted by the military that offered only the Moscow perspective on the conflict, and little or no opportunity for independent reporting on the ground.
While most Russian media voluntarily followed these government regulations and overtly supported Russias campaign in Chechnya, those that did not often faced sanctions. For example, in mid-January 2000, Russian forces detained Andrei Babitsky, a Radio Liberty correspondent and vocal critic of Russias policies in Chechnya, when he traveled there independently. They took him to a detention center, where he was beaten several times. He was later released to an unknown Chechen group and eventually resurfaced in the neighboring region of Dagestan.9 In February 2001, federal forces detained Anna Politkovskaya of the weekly newspaper Novaia Gazeta, another vocal critic who defied the Kremlins access regulations,in Khatuni while she was investigating abuses by Russian troops in the region, interrogated her and kept her overnight on a military base before releasing her the next day.10 Over the years, Russian forces have also detained a number of foreign journalists who entered Chechnya independently and the government has threatened them with withdrawal of their accreditation.11
At the outset of the new conflict, the press ministry banned Russian television channels from airing any footage of or interviews with rebel leadersa ban that was later extended to the print media.12 The government has since threatened numerous Russian media outlets with sanctions for featuring interviews with rebel leaders, and has protested those that have appeared in the foreign press.13 In July 2005, after U.S. television channel ABC aired an interview with rebel leader Shamil Basayev, the government took the unprecedented step of announcing that it would not renew accreditation for ABC correspondents.14
In 2000, the government also took the first steps in what would turn into a campaign against all television channels it did not have editorial control over. Its first target was ORT, or Channel 1, a channel that was partially owned by the state and partially by businessman Boris Berezovsky, with the latter exercising editorial control. In the run-up to the parliamentary and presidential elections in 1999 and 2000, the channel had overtly promoted Vladimir Putin and his allies, and had spearheaded a campaign against their opponents, but some time after the elections Boris Berezovsky fell out of favor. In August 2000, ORT provided critical coverage of the sinking of the Kursk submarine, broadcasting interviews with the wives of Kursk sailors criticizing the governments response to the tragedy, and producing a furious reaction from the Kremlin.15 A month later, in September 2000, Berezovsky wrote an open letter to President Putin in which he charged that a senior Kremlin official had pressured him to sell his stake in ORT. Berezovsky has claimed that when he initially refused to hand over the shares, the Kremlin had one of his business partners arrested and offered him a deal: the release of his business partner in exchange for the ORT shares. According to Berezovsky, he then negotiated for the government to pay the equivalent of U.S.$170m of the U.S.$380m he had invested in ORT and handed over the shares.16 In that same period, law enforcement agencies also raided ORTs headquarters, ostensibly looking for contraband foreign videos and evidence of alleged financial irregularities at ORT between 1997 and 1999. Eventually, Berezovsky went into self-imposed exile to try to avoid what he saw as persecution.
In mid-2000, the authorities also moved against NTV, the flagship station of oligarch Vladimir Gusinskys media empire Media Most. At the time, NTV was the largest independent television station and one of the few to provide any critical coverage of the military campaign in Chechnya. On May 11, 2000, heavily armed security forces conducted a raid on the offices of Media Mostthe first of manyand forcibly held dozens of employees in the building for a full day. Law enforcement agencies denied any political motives, but the press and many observers saw the heavy-handed raid as a warning to independent media. In June, the authorities filed criminal charges against Gusinsky and held him in custody for several days. In late July, prosecutors dropped these charges after Gusinsky agreed to transfer control over Media Most to the state-owned gas company Gazprom.17 The European Court of Human Rights, which later examined these events, concluded that the authorities had used the prosecution to pressure Gusinsky into transferring Media Most shares to Gazprom. It ruled that the prosecution had violated human rights norms, observing that it is not the purpose of such public-law matters as criminal proceedings and detention on remand to be used as part of commercial bargaining strategies.18
Upon gaining control of Media Most in April 2001, Gazprom ousted NTVs board and appointed Boris Jordan, a U.S. businessman of Russian descent, as the new executive director for the station. Under Jordan, the channel maintained for another eighteen months its previous standard of reporting and did not shy away from criticism of the Kremlin. In October 2002, the station gave extensive and critical coverage of the hostage crisis at a Moscow theater, which resulted in more than one hundred deaths when Russian security forces pumped gas into the theater to subdue the hostage takers. Shortly after, President Putin singled NTV out for criticism of its coverage of the tragedy. A few months later, in January 2003, NTVs board ousted Jordan. NTVs news coverage began to change in quality and tone after this, gradually become less and less critical of the Kremlin.19
In late 2001, LukOil-Garant, a partially state-owned oil company, moved against yet another independent television station, TV-6. It filed suit to liquidate the parent company of TV-6, in which it had a minority stake but which was controlled by Boris Berezovsky. After Gazproms takeover of NTV, TV-6 had become a prominent independent channel and was often critical of the Kremlin. In September 2001, a Moscow court ruled in favor of LukOil, and, by the end of January 2002, TV-6 went off the air. Although the government maintained that the clash between LukOil and the parent company of TV-6 was nothing but a business dispute, many media professionals and political analysts saw the hand of the Kremlin in the affair.20
In March 2002, Russias press ministry granted TV-6 a new broadcasting license, in an apparent move to stave off criticism of Russias free press record. TVS, as the new television station was called, went on air in July 2002 and broadcast news bulletins that were often very critical of the Kremlin. In June 2003, however, Russias press ministry shut down the channel, citing TVSs financial difficulties. The channels editor-in-chief attributed these financial problems to a Kremlin-controlled campaign to deprive the station of funds.21 The press ministry subsequently gave TVSs license to a sports station.22
Thus, by mid-2003, the Kremlin had established firm control over all television channels with significant national reach.23 A number of other media outlets have managed to remain independent and critical but many of them have faced constant Kremlin pressure. Radio Ekho Moskvy is the only broadcast news outlet that reaches a significant part of the Russian population and has managed to maintain its independence, despite repeated attempts by the Kremlin and its proxies to take over editorial control.24 The print press continue to reflect diverse opinions, but newspapers reach only a small minority of Russians and the Kremlin has been closing in on a number of these publications.25 At the time of this writing, government officials were calling for increased control over the Internet, including censorship of web pages, heightening fears that even the news sites on the Internet may become targets of government meddling and, no doubt, increasing self-censorship already exercised by many Internet publications.26
When Vladimir Putin came to power in 1999, regional leaders were a force to be reckoned with in Russian politics. They not only dominated their regions but also held seats in the upper chamber of Russias parliament, the Federation Council, and thus played a key role in national legislative processes. Many of the governors ran their regions as personal fiefdoms and took them on a course of great autonomy from the center. Upon becoming president, Putin quickly moved to reign in the regional leaders and has subsequently gradually eliminated them as an independent political force.
Shortly after being elected president, Putin created a new administrative layer answerable to him alone, dividing Russia into seven administrative regions led by his appointees. The super governors, as the appointees became known, were supposed to help the Kremlin control the activities of the governors in Russias regions. Putin then forced legislation through parliament to strip regional governors of their seats in the Federation Council. He justified these reforms as necessary to prevent the disintegration of Russia.
In the next few years, the Kremlin used its sway over television media and its enormous administrative resources to influence gubernatorial election campaigns, eventually making Kremlin support almost a condition for becoming governor. As a result of this effort at what some analysts have termed an aspect of managed democracy, most regional leaders became indebted to the Kremlin for support of their candidacy during the elections, and reluctant to stand up to its policies after being elected, even if the policies were not in their interests or those of their regions.
In September 2004, after the Beslan massacre, President Putin proposed scrapping direct popular elections for governors altogether, making them presidential appointees instead.28 Few regional leaders spoke out against the proposal, even though it effectively took away their last vestige of independence, and it became law in late 2004. Under the new procedure, the president nominates a candidate for governorship, who is then confirmed by the regional parliament. If a regional legislature refuses to approve a presidential nominee three times (the presidents second or third proposal can be either the original or a different nominee), the president has the right to dissolve the parliament. Since early 2005, President Putin has nominated twenty-eight regional leaders, twenty-two of whom were incumbents. Regional parliaments confirmed all the nominees swiftly.
During President Boris Yeltsins years in power, the State Duma and the Kremlin were in a perpetually adversarial relationship. While the State Duma was not an effective legislative institution in those yearsit was so divided that it was unable to adopt laws on many key issuesparties of various political persuasions were represented in it and vigorous debate on all manner of policy issues was the order of the day. Today, parliament is little more than a rubber-stamp body for President Putins proposals. Public debate on key policy issues has all but disappeared, opposition parties have been decimated or eliminated altogether, and there is evidence that freedom of speech within the ruling party is suppressed.
Soon after Vladimir Putin was appointed prime minister in the summer of 1999, the Kremlin launched its effort to ensure the December 1999 parliamentary elections resulted in a more cooperative State Duma. Vladimir Putin explicitly lent his support to the political party Yedinstvo, or Unity, and, to a lesser extent, to the Soiuz pravykh sil, or Union of Right Forces. Television channel ORT, then still controlled by Boris Berezovsky, strongly promoted Unity, and attacked its main opponents. During the elections, Yedinstvo obtained about a quarter of the vote and became the second largest party in the new State Duma. In April 2001, Yedinstvo and Otechestvo/Vsya Rossia (Fatherland/All Russia), the fourth largest political bloc in parliament, set up a joint council to oversee a merger of the two forces, which eventually took place in December 2001.29 The new party commanded more than 130 seats in the 450-seat State Duma.30 As several political blocks in parliament generally supported the pro-government coalition of Yedinstvo and Otechestvo/Vsya Rossia, the State Duma approved practically all government and Kremlin proposals. Within this largely compliant new parliament opposition parties from across the political spectrum were nevertheless represented, including the Communist Party, Yabloko, and the Union of Right Forcesdespite Vladimir Putins pre-election support this party opposed many of his policies. These parties ensured vivid public discussion of legislative initiatives and government policy, even though they eventually had little real influence on either.
Prior to the December 2003 elections, the government moved to establish even more control over the State Duma. This time, Kremlin-controlled television channels promoted Yedinaia Rossia, or United Russia, the successor of Unity, and, to a lesser extent, Rodina, or Motherland, a new political force, while attacking other parties. International election monitoring bodies observed that broadcast media outlets displayed such favoritism towards United Russia that the democratic norms of voter access to information and equal conditions for candidates and parties to convey their message to the electorate were severely compromised.31 Not surprisingly, United Russia overwhelmingly won the elections. It now controls more than two-thirds of all seats in the State Duma, enough to adopt any law or even change the constitution.32 Moreover, two liberal opposition parties, Yabloko and the Union of Right Forces, were eliminated from parliament and the Communist Party was decimated.33 Policy debate in Russia is now primarily conducted by the pro-Kremlin party, United Russia, the Communist Party, and two nationalist parties, Motherland and the Liberal Democratic Party of Russia, led by Vladimir Zhirinovskii.
After the Beslan massacre, President Putin announced and pushed through amendments to election laws that end single-mandate constituency votinguntil then, parliamentarians elected from local constituencies made up half of the State Duma, the other half being elected from party listsand introduced new membership requirements for political parties. The new rules for registering political parties introduce a minimum threshold of 50,000 members, as opposed to 10,000 previously. Additionally, political parties must receive a minimum of 7 percent of the votes in parliamentary elections to clear the entry threshold for the State Duma.
These changes are likely to lead to an even more monolithic State Duma. As most liberal opposition members in the current State Duma were elected on single mandatestheir parties failed to reach the then 5 percent threshold in the election and are unlikely to be able to participate in the 2007 elections due to changes to legislation on political partiesthe abolition of single-mandate seats is likely to eliminate these voices of dissent in the next parliamentary elections. Few parties will be able to attract more than 50,000 members, and will thus be blocked from participating in the elections; at present, only the Communist Party and United Russia have the requisite number of members. Even if parties are able to overcome the membership hurdle, they need to obtain at least 7 percent of the vote.
Following the 2003 elections, United Russia has used its two-thirds majority in the Duma to push through the Kremlins agenda and to stifle critical examination of draft bills. Its domination of the State Duma has resulted in an atmosphere of intolerance for dissenting opinions, even within its own ranks. In November 2004, United Russia deputy Anatoly Yermolin complained in an open letter addressed to the Prosecutor Generals Office, the Constitutional Court and the Speaker of the Duma that a senior official from the presidential administration had, during a meeting with United Russia deputies, ordered them to vote as the Kremlin instructed them. Several days later, Yermolin was expelled from the United Russia faction and the chairman of the Duma Management Committee, Oleg Kovalyov, accused him of being a spy of some political forces, such as [former Yukos CEO Mikhail] Khodorkovsky.34
Compromising the Independence of the Judiciary
In the 1990s, Russias judiciary made important steps towards becoming independent from the executive not just in law but also in practice. However few in Russia doubt that the Kremlin has been trying to reverse that process in the past five years. Although it is difficult to measure the extent to which the Kremlin seeks to influence the decisions of the judiciaryfew judges have come forward with allegations of pressureopinion polls show that few Russians believe that the courts are independent and observers increasingly refer to the return of telephone justice, a Soviet-era practice by which judges received instructions from the Communist Party or the KGB (state security committee) before issuing judgments.35
There is consensus among human rights groups and most Russia-watchers that at least in a number of high profile cases pressure has been exerted by the Kremlin or other political leaders on the judiciary to obtain a desired verdict. The International Bar Association, which conducted research into judicial independence in Russia in early 2005, concluded in a report that:
it is apparent that a number of high profile cases have given rise to a widespread public perception of political and or economic influence over the judiciary. These cases have the unfortunate effect of reducing public confidence in the judiciary and eroding the confidence of the judiciary itself to withstand pressure, particularly with politically sensitive cases.36
Some of the cases where the administration evidently exerted pressure on the courts include the following:
After the Beslan massacre, Sergei Mironov, the speaker of the Federation Council and an ally of President Putin, proposed measures that would dramatically increase executive control over the Supreme Court Qualification Collegium, the body that supervises the appointment, promotion, and dismissal of judges.
At present, the Qualification Collegium is composed of twenty-nine members. The All-Russian Congress of Judges selects (every four years by secret ballot) eighteen judges to serve on this body, the Federation Council selects ten members of the public, and the president appoints one representative. Under the Mironov proposal, the number of members of the Supreme Court Qualification Collegium would be reduced to twenty-one: the president would nominate ten judges who would be confirmed by the Federation Council, the speaker of the Federation Council would nominate ten members of the public who would be confirmed by the chamber, and the president would appoint a representative. Under the proposal, the make-up of regional Qualification Collegia would also be changed. Of their seventeen members, regional judges would appoint eight fellow judges, the legislative body of the region would appoint eight representatives of the public, and the president would appoint one representative. The proposal also suggested reducing the quorum for meetings of Qualification Collegia, including the Supreme Collegium, from two-thirds to a simple majority, meaning a judge could be fired without a single one of his peers being present.
Although the Federation Council overwhelmingly supported the proposal in late September 2004 and a draft law was subsequently submitted to the State Duma, the legislation has not been adopted as yet. Indeed, the International Bar Association found during its April 2005 fact-finding mission that while State Duma staff characterized the proposals as priority, most of its interlocutors did not believe the proposals would pass in their present form.42
 Text of Putin Speech, Agence France Presse, September 4, 2004.
 For an English-language transcript of the interview with President Putin, see: [online], http://kremlin.ru/eng/speeches/2004/11/18/1705_79606.shtml (retrieved November 19, 2004).
 Daisy Sindelar, 2004 And Beyond: In Russia, Tragedy Furthers Kremlin Vision Of Centralized State, Radio Free Europe/Radio Liberty, December 15, 2004.
 President Putins Annual Address to the Federal Assembly, April 25, 2005 [online], http://www.kremlin.ru/eng/speeches/2005/04/25/2031_type70029_87086.shtml (retrieved August 31, 2005).
 Human Rights Watch, World Report 2000 (New York: Human Rights Watch, 2000) [online], http://www.hrw.org/wr2k/Eca-17.htmhttp://www.hrw.org/wr2k/Eca-17.htm (retrieved August 22, 2005).
 Human Rights Watch, World Report 2001 (New York: Human Rights Watch, 2001) [online], http://www.hrw.org/wr2k1/europe/russian.html (retrieved August 22, 2005).
 Human Rights Watch, World Report 2002 (New York: Human Rights Watch, 2002) [online], http://www.hrw.org/wr2k2/europe16.html (retrieved August 22, 2005).
 Foreign Ministry confirms foreign newsmen in Chechnya released, BBC Monitoring Service: Former USSR, December 31, 1999; Committee to Protect Journalists (CPJ), Russia 2000: Country Report [online], http://www.cpj.org/attacks00/europe00/Russia.html (retrieved August 23, 2005); Ann Cooper, Russia: CPJ calls on minister to reverse ABC decision, Committee to Protect Journalists, March 24, 2005.
 Human Rights Watch, World Report 2002 (New York: Human Rights Watch, 2002) [online], http://www.hrw.org/wr2k2/europe16.html (retrieved August 22, 2005).
 For example, in February 2005, Russias Foreign Ministry criticized the decision by the United Kingdoms Channel 4 News to broadcast an interview with Shamil Basayev (See: Jill Dougherty, Basayev interview angers Moscow, CNN.com, February 4, 2005 [online], http://edition.cnn.com/2005/WORLD/europe/02/04/basayev/ (retrieved August 23, 2005); in March 2005 Russia also criticized the Swedish news agency TT for broadcasting an interview with Basayev (See: Russia: CPJ calls on minister to reverse ABC decision, Committee to Protect Journalists, March 24, 2005).
 Nabi Abdullaev, ABC Case Looks Like a Populist Warning, Moscow Times, August 4, 2005.
 How democracy was rolled back in Russia in drive to consolidate his power, Putin minimized risks and forced TV to submit, The Washington Post, June 8, 2005.
 Moscows most wanted man Billionaire Boris, The Observer (London), April 27, 2003.
 Human Rights Watch, World Report 2001 (New York: Human Rights Watch, 2001) [online], http://www.hrw.org/wr2k1/europe/russian.html (retrieved August 23, 2005); Committee to Protect Journalists, Russia 2000: Country Report [online], http://www.cpj.org/attacks00/europe00/Russia.html, (retrieved August 23, 2005).
 European Court of Human Rights, Case of Gusinskiy v. Russia, Judgement, First Section, Part II (B), paragraph 76, Strasbourg, May 19, 2004.
 International Press Institute, 2004 World Press Freedom Review: Russia [online], http://www.freemedia.at/wpfr/Europe/russia.htm (retrieved August 24, 2005).
 Andrew Jack, Self-censorship the way to stay on air, Financial Times (London), April 15, 2005.
 Editor of last Russian independent TV warns of threat of shutdown, Agence-France Presse, June 18, 2003.
 Fear for Media Freedom as Russia shuts independent TVS, BBC Monitoring, June 26, 2003.
 Most regional television channels are under the control of the respective governors. See, for example, Human Rights Watch, World Report 2005 (New York: Human Rights Watch, 2005), p. 407.
 Since Gazproms takeover of Gusinskys Media-Most empire in 2001, Gazprom has held 66 percent of Ekho Moskvys shares, with journalists controlling the remaining 34 percent. Between 2001 and 2004, the station lost broadcasting contracts in fifty cities across the country and can now be received in only thirty-nine regions (See: Anna Dolgov, The Kremlins Harmful but Beautiful Insect, Moscow Times, January 29, 2004). The radio stations editor-in-chief Alexei Venediktov maintains that Ekho Moskvy is under constant pressure from the authorities over its coverage (Eric Helque, Last mic standing, Russian Life, January 1, 2005), and that he and his colleagues have received anonymous threats to their safety and that of their families (Scott Petersen, Grip of Putins censors tightens, Christian Science Monitor, June 8, 2004).
 See for example: Committee to Protect Journalists, Attacks on the Press 2003: Russia [online], http://www.cpj.org/attacks03/europe03/russia.html (retrieved August 24, 2005); Chris Stephen, Kremlin tightens screws on media as Gazprom buys into Izvestia, Irish Times, June 13, 2005.
 Reiman says mass media law should regulate Internet, Prime-Tass News, March 22, 2005.
 The Russian Federation consists of 89 federal subjects. These subjects are divided into 21 republics, 49 provinces (oblast in Russian), 6 regions (krais in Russian), 1 autonomous oblast (avtonomnaia oblast in Russian), 10 autonomous districts (avtonomy okrug), and the 2 federal cities of Moscow and St Petersburg. Region is used here to denote a federal subject. See: Reference.com [online], www.reference.com/browse/wiki/Federal_subjects_of_Russia, (retrieved October 17, 2005).
 Vladimir Putin, Speech at the Enlarged Meeting with the Government and Heads of the Regions, September 13, 2004 [online], http://www.kremlin.ru/english/speeches/2004/09/13/0000_type82912type82913_76667.shtml (retrieved August 24, 2005).
 Diana Rudakova, Fatherland-Unity merger council to meet on April 20, ITAR Tass, April 13, 2001; and Europe Review World of Information, Russia Review, October 3, 2002.
 Dario Thuburn, Kremlin Backs Election Rule Change, WMRC Daily Analysis, October 9, 2002.
 OSCE/ODIHR Election Observation Monitor Report Russian Federation Elections to the State Duma, December 7, 2003 [online], http://www.osce.org/documents/odihr/2004/01/1947_en.pdf (retrieved March 18, 2005).
 The United Russia faction (comprising United Russia deputies and their allies) holds 306 out of 450 seats in the State Duma.
 The Communist Party went from 113 seats in the 1999 State Duma to 51 in the 2003 State Duma.
 Francesca Mereu, United Russia Expels Critical Deputy, Moscow Times, November 10, 2004. For further reference to Mikhail Khodorkovsky see below.
 Russian TV examines lack of public confidence in judiciary, BBC Monitoring, April 5, 2005; and Michael G. Goldhaber, Crime and Punishment, The Recorder, August 12, 2004.
 International Bar Association Human Rights Institute, Striving for Judicial Independence: A Report into Proposed Changes to the Judiciary in Russia, June, 2005 [online], http://ibanet.org/images/downloads/2005_06_June_Report_Russia_Striving%20for%20Judicial%20Independence_Final_English.pdf (retrieved August 24, 2005).
 Ariel Cohen, Verdict with chilling fallout, Washington Times, June 8, 2005.
 Parliamentary Assembly of the Council of Europe, Resolution 1418 (2005), The circumstances surrounding the arrest and prosecution of leading Yukos executives, January 25, 2005 [online], http://assembly.coe.int/Main.asp?link=http://assembly.coe.int/Documents/AdoptedText/ta05/ERES1418.htm (retrieved August 18 2005).
 See: Human Rights Watch press release, Russia: Art Conviction Undermines Free Expression, March 28, 2005.
 Joint statement on the case of Igor Sutiagin, Amnesty International, Human Rights Watch, the International Helsinki Federation for Human Rights, the Moscow Helsinki Group, and the Public Committee for the Protection of Scientists, June 2004, [online] http://hrw.org/backgrounder/eca/russia/2004/igor_statement.htm (retrieved August 25, 2005); Human Rights Watch, Russia: Pretrial Detention Excessive in Espionage Case, October 27, 2003 [online], http://hrw.org/press/2003/10/russia102703.htm (retrieved August 25, 2005); Human Rights Watch, Fair Trial Needed for Nuclear Scientist, August 16, 2004 [online], http://hrw.org/english/docs/2004/08/16/russia9234.htm (retrieved August 25, 2005); Russia: Fair Trial Needed in Spy Case, June 2, 2004 [online], http://hrw.org/english/docs/2004/06/02/russia8677.htm (retrieved August 25, 2005).
 The defense for Valentin Danilov alleged that his research was based on open-source materials. However, at the trial, the judge did not allow Danilovs defense team to present information about his sources to the jury, thus preventing him from mounting a genuine defense. See: Fred Weir, Whistleblowers face a chill wind in Putins Russia, Amnesty International Magazine, Summer 2005 [online], http://www.amnestyusa.org/magazine/whistleblowers.html (retrieved August 25, 2005).
 International Bar Association, Striving for Judicial Independence: A Report into Proposed Changes to the Judiciary in Russia, June 2005 [online], http://www.ibanet.org/images/downloads/2005_06_June_Report_Russia_Striving%20for%20Judicial%20Independence_Final_English.pdf (retrieved August 24, 2005).