Indeed, in Chiragov v. Armenia, the Grand Chamber of the European Court of Human Rights considered the matter (see also Sargsyan v.Azerbaijan and discussion). The Grand Chamber discussed how the NKR is integrated into and dependent on Armenia. For example, its residents are issued Armenian passports; politicians hold, at different times, positions in both Armenia and the NKR; Armenian law-enforcement agencies operate in the territory; and Armenian courts exercise jurisdiction in it (paras. 78 and 182). Based on these and other relevant facts, it concluded that “the ‘NKR’ and its administration survive by virtue of the military, political, financial and other support given to it by Armenia which, consequently, exercises effective control over Nagorno‑Karabakh and the surrounding territories, including the district of Lachin” (para. 186).
Indeed, the international community has regularly characterized Nagorno-Karabakh and the surrounding area as occupied by Armenia. As noted, the UN Security Council did so in four resolutions in 1993 alone. For example, the first “[d]emand[ed] the immediate cessation of all hostilities and hostile acts with a view to establishing a durable ceasefire, as well as immediate withdrawal of all occupying forces from the Kelbadjar district and other recently occupied areas of Azerbaijan” (UNSCR 822). Like the other three, it “[r]eaffirm[ed] . . . respect for sovereignty and territorial integrity of all States in the region,” as well as “the inviolability of international borders and the inadmissibility of the use of force for the acquisition of territory.”