The 1994 Baku Metro Bombing and the Maksimov Judgment

Legal boundary: The domestic conviction and the later European human-rights judgment answer different questions. The ECHR found the 2005 cassation process unfair; it did not reweigh the bombing evidence, declare Maksimov innocent or itself set aside the conviction.

The bombing at “20 January” station

On 19 March 1994, an explosive device detonated on a Baku Metro train as it entered or stood at the station then widely identified in English-language records as “20 January.” The station name commemorates the Soviet crackdown of January 1990, making the attack’s location especially prominent in Azerbaijan’s public memory.

The factual section of the European Court of Human Rights judgment in Maksimov v. Azerbaijan records 14 deaths and 50 injuries. Retrospective government and news accounts have sometimes reported a lower injury total—most often 49 or 42. Because the number of people wounded varies across otherwise credible records, this archive uses the ECHR’s 14-dead, 50-injured formulation for the principal count and does not flatten the discrepancy into false certainty.

Among those killed was jazz pianist and composer Rafig Babayev. His death gave the mass-casualty attack an additional cultural resonance, but the other victims are not reduced to an anonymous number here: each was a person caught in an ordinary public-transport journey. Graphic descriptions add nothing necessary to understanding the crime and are omitted.

A period of instability and a second metro attack

The bombing occurred during the first years of Azerbaijan’s independence, amid political turmoil, the war over Nagorno-Karabakh and serious internal-security concerns. A separate explosion struck the Baku Metro on 3 July 1994. Official histories and later reporting often discuss the two attacks together, but this page is limited to the March bombing and the prosecution reviewed in Maksimov’s case. Treating two explosions as one incident would obscure distinct evidence and legal records.

Azerbaijani authorities attributed the March attack to an organized group and prosecuted Maksimov as a participant. Those claims are presented as the prosecution case and as findings embodied in the domestic judgment—not as an independent editorial conclusion about every alleged connection or motive. The public record available in English is far clearer about the procedural history than about all the evidence heard at the original trial.

Arrest, charges and the 1996 judgment

Rahib Shaval oglu Maksimov was arrested in 1994. According to the later ECHR judgment, prosecutors accused him of participating in the preparation and execution of the bombing as part of an organized group. Proceedings were conducted under Azerbaijan’s 1960 Criminal Code and the criminal-procedure rules then in force.

On 3 May 1996, the Supreme Court of Azerbaijan, acting as the trial court for the case, convicted Maksimov of multiple offenses arising from the bombing. It sentenced him to death and ordered confiscation of his property. Under the procedure in place at the time, the judgment was final and no ordinary appeal was available.

The description “convicted” therefore rests on a domestic court judgment. It does not mean every allegation made around the attack is independently verified, and it does not erase the later finding that a review proceeding was conducted unfairly. These distinctions are essential in a case where the original verdict, a change in punishment and a human-rights judgment are sometimes compressed into a single sentence.

Abolition of the death penalty

Azerbaijan abolished capital punishment on 10 February 1998. The legislative change automatically commuted outstanding death sentences, including Maksimov’s, to life imprisonment. He was not executed.

The commutation changed the punishment but did not itself reopen the factual findings supporting the conviction. Later procedural reforms did create a route by which defendants convicted under the earlier system could ask the Supreme Court to review old judgments through cassation proceedings.

The 2005 cassation proceedings

Maksimov used the new procedure to challenge his conviction and sentence. The Supreme Court considered his cassation appeal on 12 April 2005 and dismissed it. A further application went to the Plenum of the Supreme Court, which considered the matter on 24 November 2005. The Plenum adjusted the legal classification of offenses to provisions of the newer Criminal Code but left the life sentence in place.

The central problem was notice and participation. Maksimov said he was not summoned to either hearing and learned of the outcomes afterward. The prosecution was represented. The later Strasbourg judgment found no evidence establishing that he had waived attendance knowingly or that the authorities had duly informed him of the hearing.

This was not a minor administrative defect. Cassation was the first opportunity created by transitional legislation for judicial scrutiny of a death-sentence-era conviction that had originally been final at first instance. The way that review was conducted therefore mattered to the practical fairness of the proceedings as a whole.

What the European Court decided

On 8 October 2009, the European Court of Human Rights delivered judgment in Maksimov v. Azerbaijan. It held that the absence of proper notice, combined with the prosecutor’s participation while Maksimov was absent, violated Article 6 § 1 of the European Convention—the right to a fair hearing.

The Court emphasized equality of arms and the defendant’s ability to participate effectively. It concluded that the proper form of redress would be measures allowing the cassation appeal to be reopened and examined in proceedings meeting Article 6 requirements. The judgment awarded no rewrite of the historical facts and did not substitute Strasbourg judges for the Azerbaijani criminal court.

Other complaints, including arguments connected to the replacement of the death sentence with life imprisonment, were not accepted as establishing a further Convention violation. Accordingly, the accurate headline is narrow: a domestic conviction remained on record, but the process used to review it in 2005 was unfair.

Later procedural status

A 2016 Azerbaijani news report said Maksimov intended to lodge another Supreme Court appeal concerning his sentence and the execution of the ECHR judgment. This confirms that the procedural consequences remained contested years after Strasbourg’s decision. It does not, by itself, establish that a new hearing occurred or that the conviction was later quashed.

Through 30 September 2026, this review did not locate a reliable public judgment documenting a final reopened cassation outcome that displaced the 1996 conviction or the life sentence. The page therefore classifies the file as adjudicated, with a documented fair-trial violation in later review proceedings. If a conclusive later ruling becomes verifiable, the classification and chronology should be updated.

What is established—and what is not

Established in the reviewed record: a bomb killed 14 people at the “20 January” station on 19 March 1994; Maksimov was convicted and sentenced to death in 1996; abolition of capital punishment commuted the sentence to life in 1998; and the ECHR found the 2005 cassation proceedings incompatible with Article 6 § 1.

Not established by the ECHR: that Maksimov was innocent, that the bombing did not occur as described by domestic authorities, or that every prosecution allegation was correct. The Court assessed procedural fairness, not criminal guilt. Nor does the available English-language record resolve the varying injury totals or document a final post-2009 reopening result.

Timeline

1. 19 March 1994
   A bomb explodes at Baku Metro’s “20 January” station. The ECHR record states that 14 people are killed and 50 injured.
2. 1994
   Rahib Maksimov is arrested and prosecuted in connection with the attack.
3. 3 May 1996
   Azerbaijan’s Supreme Court convicts Maksimov, sentences him to death and orders confiscation of property.
4. 10 February 1998
   Azerbaijan abolishes the death penalty; the sentence is automatically commuted to life imprisonment.
5. 12 April 2005
   The Supreme Court dismisses his cassation appeal in his absence.
6. 24 November 2005
   The Supreme Court Plenum reclassifies offenses under the newer code but leaves the life term intact.
7. 8 October 2009
   The ECHR finds an Article 6 § 1 violation in the cassation proceedings.
8. 2016
   A news report says Maksimov plans a further Supreme Court appeal.
9. 30 September 2026
   No verified final later ruling displacing the conviction or life sentence was located.

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