AS/Jur (2023) 17 56. In the Razvozzhayev case both States had jurisdiction over the facts which had occurred on their territories, with a special jurisdictional link with Russia established on the basis of its authority and control allegedly exercised through its agents operating abroad. Although the Court found no evidence that the abductors had acted on behalf of Russia or that the Ukrainian authorities had been complicit, both States were held responsible under Articles 3 (prohibition of torture) and 5 (right to liberty) of the Convention for the failure to conduct an effective investigation into the applicant’s allegations of abduction and ill-treatment committed on their territories or by their agents. In Rantsev the jurisdiction of Russia was determined by the fact that the alleged trafficking had commenced on its territory, and therefore triggered its positive and procedural obligations to protect the victim from trafficking and to investigate the trafficking, in particular the recruitment of the victim (under Article 4 of the Convention, which prohibits slavery and forced labour). Russia was also under a procedural obligation (under Article 2) to cooperate with the investigation into the victim’s death conducted by Cypriot authorities, for instance by securing the evidence located on its territory following a legal assistance request. By analogy, the Court could examine the responsibility for various forms of transnational repression originated in persecutor States with effects in other States, such as issuing politically motivated Interpol Red Notices or passport cancellation, denial of consular services, intimidation, surveillance, coercion by proxy, etc. 57. The concept of jurisdiction and responsibility is also applicable the other way around, in respect of the host States bearing positive obligations to protect individuals from transnational repression. The Court settled this principle in its leading case of Soering, with reference to the decision to extradite an individual that engaged the State’s responsibility under the Convention where a risk existed that the person would be tortured or otherwise ill-treated80 or faced the risks of a flagrant denial of justice in a third State81. The series of cases concerning extra-legal renditions to the CIA within the territories of Poland82, Romania83, Lithuania84 and North Macedonia85 have just reconfirmed this principle, acknowledging the complicity of these States for serious violations of human rights committed on their territories by foreign agents. Accordingly, any host State adopting a decision to arrest, detain and render a person following a request from a persecuting State might bear responsibility for the removal or transfer, where there is a real risk of being subjected to a violation of the Convention (of Articles 2 or 3, or a flagrant breach of Articles 5 or 6) in or by the persecuting State. Similarly, host States should be regarded as responsible under the Convention for internationally wrongful acts performed by foreign officials on its territory with the acquiescence or connivance of its authorities. More generally, a positive obligation might arise (under Articles 2 and 3) for host States to protect within their territory potential targets of transnational repression by agents of third States, if the authorities know or should know of the existence of a real and immediate risk to the life or physical integrity of such persons. 86 58. States can also bear responsibility for being co-opted or complicit in acts of transnational repression. In the case of Ozdil and others (referred to above), the Court held the Republic of Moldova responsible for depriving the applicants of their liberty in a manner amounting to an extra-legal transfer from its territory to Türkiye, which circumvented all guarantees offered to persecuted individuals by domestic and international law. In this and other similar cases, such as Shenturk and Others v. Azerbaijan87 (extra-legal transfers to Türkiye), Shorazova v. Malta88 (freezing assets at the request of Kazakh authorities, likely tainted by political persecution), Garabayev v. Russia89 (arrest in breach of domestic law and extradition to Turkmenistan with awareness of a real risk of ill-treatment) or Abdulkhakov v. Russia90 (secret transfer to Tajikistan with a risk of removal to Uzbekistan) the Court no longer questioned whether the authorities of the host State retained jurisdiction. 80 Soering v. the United Kingdom, No. 14038/88, 07 July 1989. Othman (Abu Qatada) v. the United Kingdom, No 8139/09, 17 January 2012. 82 Al Nashiri v. Poland, No 28761/11, 24 July 2014. 83 Al Nashiri v. Romania, No 33234/12, 31 May 2018. 84 Abu Zubaydah v. Lithuania, No. 46454/11, 31 May 2018. 85 El-Masri v. “the former Yugoslav Republic of Macedonia” [GC], No. 39630/09, 13 December 2012. 86 Applying the Osman test, Osman v. the United Kingdom, 28 October 1998. For Article 3, see X and Others v. Bulgaria [GC], No. 22457/16, 2 February 2021.The Court has not yet applied these principles in a purely transnational repression case. 87 Shenturk and Others v. Azerbaijan, nos. 41326/17 and other applications, 10 March 2022. 88 Shorazova v. Malta, no 51853/19, 03 March 2022. 89 Garabayev v. Russia, no 38411/02, 07 June 2007. 90 Abdulkhakov v. Russia, No. 14743/11, 02 October 2012. 81 18