On June 16, 2015, the European Court of Human Rights (ECHR or the Court) released its judgment in Chiragov and Others v. Armenia, finding that the rights of Azerbaijani refugees had been violated by their inability to return to property in an area under Armenia’s control. The judgment, which centers on a long-standing, “frozen” territorial armed conflict in Nagorno-Karabakh, develops the Court’s jurisprudence on extraterritoriality. The intervention of Azerbaijan in the case makes it into a pseudo interstate dispute. Finally, although not the focus of this note, the application of the Pinheiro Principles to adjudicate mass population transfer is praiseworthy for its advancement of the contribution of human rights law to conflict resolution.