Cases / Protected area / relocation · Greece · 1986–2025
Laganas Bay, Zakynthos, Greece: National Marine Park, Bern file 1986/8 and CJEU C-103/00 (2002)
Nature's voice · report
In 2025, 28 of my turtles stranded at Laganas Bay, 25 of them dead; in 2002 the Court of Justice found Greece had failed to fulfil its obligations to establish strict protection for them. ARCHELON Court of Justice of the European Union (EUR-Lex)
Recorded
- The Commission's visits in July 1998 and August 1999 found pedalos and boats in prohibited sea areas, umbrellas and deck-chairs over the limits and mopeds on the sand of my nesting beaches, and buildings at Dafni that the Commission described as illegal. Court of Justice of the European Union (EUR-Lex)
- On 30 January 2002 the Court of Justice found that Greece had failed to fulfil its obligations to establish strict protection for Caretta caretta on my island of Zakynthos. Court of Justice of the European Union (EUR-Lex)
- In 2025, 28 strandings of my turtles were recorded, of which 25 were dead and 14 were inside the Marine Park, according to ARCHELON. ARCHELON
- ARCHELON states that human pressures on my coastal and marine habitats continue. ARCHELON
Accounts of the harm differ
Whether the 1999 decree gave the nesting beaches strict protection
- Government and regulators Greece: Said Presidential Decree 906/22.12.1999 "instituted a system of strict protection". Court of Justice of the European Union (EUR-Lex)
- International bodies European Commission: Its visits of July 1998 and August 1999 found no supervision or notices on the beaches, pedalos and boats in prohibited sea areas, umbrellas and deck-chairs over the limits, buildings at Dafni it described as illegal, and mopeds on the sand. Court of Justice of the European Union (EUR-Lex)
- Courts Court of Justice of the European Union: Found (para. 40) that Greece "failed to fulfil its obligations" to establish strict protection for Caretta caretta on Zakynthos. Court of Justice of the European Union (EUR-Lex)
MEDASSET complained to the Bern Convention in 1986 about development at the loggerhead nesting beaches of Laganas Bay on Zakynthos. On 30 January 2002 the Court of Justice found that Greece had failed to fulfil its obligations to establish strict protection for Caretta caretta on the island; the Bern file was reopened in 2020 and remained open in October 2026.
About 2,155Loggerhead nests recorded in 2025 (ARCHELON)
ARCHELON's report on Laganas Bay also gives about 2,470 nests in 2024 and 2,033 in 2023 (1 December 2025).
ARCHELON's report on Laganas Bay also gives about 2,470 nests in 2024 and 2,033 in 2023 (1 December 2025).
Status As of October 2026: the Bern Convention file (1986/8) is open after being reopened in 2020; the Court of Justice judgment of 2002 stands; a 2026 Greek government report to the Bern Convention exists but was not reviewed.
What?
Tourist development and beach use at the loggerhead nesting beaches of Laganas Bay led to a Bern Convention complaint (1986), a National Marine Park (1999) and a judgment of the Court of Justice (30 January 2002) that Greece had failed to establish strict protection for Caretta caretta on Zakynthos. Court of Justice of the European Union (EUR-Lex)
Where?
Zakynthos, Greece: Laganas/Kalamaki, Sekania, Dafni, Gerakas and Marathonisi; the National Marine Park of Zakynthos. Council of Europe, Bern Convention
When?
1986 (Bern complaint) to 2025; Recommendations of 1987; Commission visits 1998 and 1999; Presidential Decree of 22 December 1999; Commission action of 17 March 2000; judgment of 30 January 2002; Bern file reopened in 2020. Court of Justice of the European Union (EUR-Lex)
Who?
Gained
None on recordLost
- Greece (Hellenic Republic) — Found by the Court of Justice in C-103/00 to have failed to fulfil its obligations; ordered to pay the costs Court of Justice of the European Union (EUR-Lex)
Harmed
- Loggerhead (Caretta caretta) nesting beaches of Laganas Bay and Zakynthos — Subject of the Court's finding; 28 strandings in 2025, 25 dead, 14 inside the Marine Park (ARCHELON) ARCHELON
Why?
The sources reviewed give no stated reason beyond the Commission's findings on supervision, boats, umbrellas, buildings and mopeds. Greece argued that its 1999 decree already instituted strict protection. Court of Justice of the European Union (EUR-Lex)
How?
MEDASSET and ARCHELON complained to the Bern Convention; the Standing Committee recommended protection; Greece created the Marine Park by decree; the Commission sued and the Court found Greece in breach; ARCHELON's monitoring has since been co-financed once by the Green Fund and otherwise largely by ARCHELON. Court of Justice of the European Union (EUR-Lex)
6 of 6 questions answered from the record
What happened
The record, in order.
In 1986 MEDASSET, supported by ARCHELON, filed a complaint with the Bern Convention about the loggerhead nesting beaches of Laganas Bay on Zakynthos. The Standing Committee adopted Recommendation No. 7 and Recommendation No. 9 in 1987, calling for legal protection of the nesting beaches and for no new tourist development there. Bern file 1986/8 was closed in December 1999, when the case went to the Court of Justice, and was reopened in 2020; it was listed as open in October 2026.
Commission visits on 16-17 July 1998 and 24-25 August 1999 found, as recorded in the judgment, no supervision or notices on the beaches, pedalos and boats in prohibited sea areas, umbrellas and deck-chairs over the permitted limits, buildings at Dafni that the Commission described as illegal, and mopeds on the sand. In 1999 a budget of GRD 30 million was approved for information, supervision, cleaning and protection of the Laganas beaches (judgment, para. 14). Presidential Decree 906/22.12.1999 created the National Marine Park of Zakynthos. The Commission sued on 17 March 2000.
In Case C-103/00 (ECLI:EU:C:2002:60) Greece argued (para. 20) that the 1999 decree "instituted a system of strict protection". On 30 January 2002 the Court found (para. 40) that Greece had "failed to fulfil its obligations" to establish strict protection for Caretta caretta on Zakynthos, and ordered Greece to pay the costs.
In 2020 the Green Fund of the Greek Ministry of Environment gave EUR 45,000 for ARCHELON's nest monitoring, which ARCHELON described as the first co-financing; in 2025 ARCHELON says recording is "largely funded by ARCHELON itself". In its report on Laganas Bay of 1 December 2025 ARCHELON recorded about 2,155 nests in 2025, 2,470 in 2024 and 2,033 in 2023, and 28 strandings in 2025, of which 25 were dead and 14 were inside the Marine Park. ARCHELON states that "human pressures on coastal and marine habitats continue" and that the Marine Park management plan has not been finalised. The Marine Park is now managed by NECCA.
The Court's judgment in C-849/19 of 17 December 2020, which found that Greece had not set conservation objectives and measures for 239 Sites of Community Importance, is not specific to turtles; the Bern file pages list Laganas Bay among the sites concerned. As of October 2026 the Bern file was open. The Commission also brought separate actions (C-600/12 and C-368/24) about a landfill inside the Marine Park.
- 1986MEDASSET, supported by ARCHELON, files the Bern Convention complaint (file 1986/8)
- 1987Bern Recommendations No. 7 and No. 9: legal protection of the nesting beaches and no new tourist development there
- 1998First Commission inspection visit to the nesting beaches (16-17 July)
- 1999Second Commission visit (24-25 August); the two visits found no supervision or notices on the beaches and boats in prohibited sea areas (judgment); budget of GRD 30 million approved; Presidential Decree 906/22.12.1999 creates the National Marine Park of Zakynthos; Bern file closed in December as the case goes to the Court of Justice
- 2000Commission sues Greece in C-103/00 (17 March)
- 2002Court of Justice judgment in C-103/00 (30 January): Greece failed to fulfil its obligations; Greece pays costs
- 2020Bern file 1986/8 reopened; Green Fund co-finances ARCHELON's nest monitoring with EUR 45,000, the first co-financing; Court of Justice judgment in C-849/19 (17 December)
- 2025ARCHELON reports about 2,155 nests, 28 strandings and continuing human pressures (1 December)
What was said
Claims, in the words of those who made them.
“instituted a system of strict protection”
“failed to fulfil its obligations”
“largely funded by ARCHELON itself”
“human pressures on coastal and marine habitats continue”
Where accounts differ
Each party's account, side by side, with its source. The record does not settle these points; it shows them.
Whether the 1999 decree gave the nesting beaches strict protection
Government and regulators
Greece
Said Presidential Decree 906/22.12.1999 "instituted a system of strict protection".
Court of Justice of the European Union (EUR-Lex)International bodies
European Commission
Its visits of July 1998 and August 1999 found no supervision or notices on the beaches, pedalos and boats in prohibited sea areas, umbrellas and deck-chairs over the limits, buildings at Dafni it described as illegal, and mopeds on the sand.
Court of Justice of the European Union (EUR-Lex)Courts
Court of Justice of the European Union
Found (para. 40) that Greece "failed to fulfil its obligations" to establish strict protection for Caretta caretta on Zakynthos.
Court of Justice of the European Union (EUR-Lex)How it looked
What was shown, beside what was recorded.
Shown
- The 1999 decree described as having "instituted a system of strict protection".Greece, in its defence before the Court of Justice (judgment, para. 20) · Court of Justice of the European Union (EUR-Lex)
Recorded
- Court of Justice, C-103/00, 30 January 2002: Greece failed to fulfil its obligations to establish strict protection for Caretta caretta on Zakynthos; Greece to pay the costs.
- Commission visits in July 1998 and August 1999 found no supervision or notices on the beaches, pedalos and boats in prohibited sea areas, umbrellas and deck-chairs over the limits, buildings at Dafni described by the Commission as illegal, and mopeds on the sand.
- A budget of GRD 30 million was approved in 1999 for information, supervision, cleaning and protection of the Laganas beaches (judgment, para. 14).
- Bern Recommendations No. 7 and No. 9 (1987) called for legal protection of the nesting beaches and no new tourist development there; file 1986/8 was closed in December 1999, reopened in 2020 and was open in October 2026.
- ARCHELON: about 2,155 nests in 2025, 2,470 in 2024 and 2,033 in 2023; 28 strandings in 2025 (25 dead), 14 inside the Marine Park.
- The Green Fund of the Greek Ministry of Environment gave EUR 45,000 for ARCHELON's 2020 nest monitoring, the first co-financing.
Who gained
Money that reached nature, beside money that stayed elsewhere.
Reached nature or the ground
Not published
Green Fund co-financing of ARCHELON's 2020 nest monitoring on Zakynthos€0.04m
The first co-financing, per ARCHELON.
Gained elsewhere
Not totalled
Budget approved for information, supervision, cleaning and protection of the Laganas beaches (judgment, para. 14)—
GRD 30 million.
Costs in C-103/00—
Greece ordered to pay the costs; amount not stated in the sources reviewed.
Currency: EUR · Window: 1999 to 2025. All figures cover the same period. * Estimate built from cited figures.
Responses on record
- Greece (Hellenic Republic) (Proceedings in C-103/00, judgment of 30 January 2002): Told the Court of Justice that Presidential Decree 906/1999 "instituted a system of strict protection". · Court of Justice of the European Union (EUR-Lex)
- ARCHELON (1 December 2025): Said nest recording in 2025 is "largely funded by ARCHELON itself" and that "human pressures on coastal and marine habitats continue". · ARCHELON
In court and with insurers
Every proceeding and every insurer decision on record.
Lawsuits and rulings
- 1986–1987OngoingBern Convention file 1986/8 (Laganas Bay, Zakynthos), Recommendations No. 7 and No. 9 (1987)Bern Convention Standing Committee (Council of Europe) · International court · MEDASSET, supported by ARCHELON → Greece
Recommendations No. 7 and No. 9 (1987) called for legal protection of the nesting beaches and no new tourist development there. The file was closed in December 1999 when the case went to the Court of Justice, reopened in 2020 and was open in October 2026. Council of Europe, Bern Convention
- 2000-03-17–2002-01-30Claimant wonCommission v Hellenic Republic, Case C-103/00 (ECLI:EU:C:2002:60)Court of Justice of the European Union · International court · European Commission → Hellenic Republic
The Court found that Greece had failed to fulfil its obligations to establish strict protection for Caretta caretta on Zakynthos and ordered Greece to pay the costs. Greece had argued that Presidential Decree 906/22.12.1999 instituted a system of strict protection. Court of Justice of the European Union (EUR-Lex)
- 2020-12-17Claimant wonCase C-849/19 (ECLI:EU:C:2020:1047): conservation objectives for 239 Greek Sites of Community ImportanceCourt of Justice of the European Union · International court · → Greece
The Court found that Greece had not set conservation objectives and measures for 239 Sites of Community Importance (Habitats Directive Articles 4(4) and 6(1)); Greek legislation of 7 May 2020 was too late to count. The case is not specific to turtles; the Bern file pages list Laganas Bay among the sites. Court of Justice of the European Union (EUR-Lex)
Insurers
No insurer decision on record.
What nature saw
Outcomes measured on the ground, and nature's note.
Nature's report opens this page. Below: further outcomes measured on the ground.
Nests recorded, 2025
About 2,155
ARCHELON report on Laganas Bay, 1 December 2025; about 2,470 in 2024 and 2,033 in 2023
Strandings, 2025
28 (25 dead)
14 inside the Marine Park (ARCHELON, 1 December 2025)
Court finding
Failure to establish strict protection for Caretta caretta
Court of Justice, C-103/00, 30 January 2002
What we don't know
Undisclosed, unproven, untried: recorded as data.
Nature
- Disputed Whether the 1999 decree gave the nesting beaches strict protection
Money
- None on record Budget approved for information, supervision, cleaning and protection of the Laganas beaches (judgment, para. 14) — GRD 30 million.
- None on record Costs in C-103/00 — Greece ordered to pay the costs; amount not stated in the sources reviewed.
Record
- None on record Not on record: whether structures at Dafni and Gerakas that are the subject of demolition orders have been removed.
- None on record Reported by ARCHELON (1 December 2025): the Marine Park management plan has not been finalised.
- Insufficient Unconfirmed: nests on Dafni beach of about 150 a year in 1984-2002 against 94 a year in 2003-2023.
- None on record Not on record: the amount of the costs Greece was ordered to pay in C-103/00.
Did the harm stop?
The Court found on 30 January 2002 that Greece had failed to establish strict protection, after the National Marine Park had been created by decree in December 1999. ARCHELON stated in December 2025 that human pressures on coastal and marine habitats continue and that the Marine Park management plan is not finalised. The Bern file was open in October 2026.
Who paid?
Greece was ordered to pay the costs in C-103/00. A budget of GRD 30 million was approved in 1999 for information, supervision, cleaning and protection of the Laganas beaches. The Green Fund gave EUR 45,000 for ARCHELON's 2020 nest monitoring; in 2025 ARCHELON says recording is "largely funded by ARCHELON itself".
Sources
Voices on record: — Company or project— Government and regulators✓ Courts— Press and investigations✓ Communities and civil society— Researchers✓ International bodies
Courts
- Judgment of the Court of 30 January 2002, Case C-103/00, Commission v Hellenic Republic (ECLI:EU:C:2002:60)Court of Justice of the European Union (EUR-Lex) · 2002-01-30
- Judgment of the Court of 17 December 2020, Case C-849/19 (ECLI:EU:C:2020:1047)Court of Justice of the European Union (EUR-Lex) · 2020-12-17
Communities and civil society
International bodies
- Bern Convention file 1986/8, Greece: Recommendation No. 9 (1987) on the protection of Caretta caretta in Laganas Bay, ZakynthosCouncil of Europe, Bern Convention ·
Connected cases
Related matters, and cases linked to this one through the same organisations, with the role each played in both.
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