CATAN AND OTHERS v. MOLDOVA AND RUSSIA JUDGMENT 35 Transdniestria consumed USD 505 million worth of gas, but paid for only 4% (USD 20 million). 94. Finally, the Moldovan Government submitted that the politics of the “MRT” were entirely orientated towards Russia and away from Moldova. There were many high-level visits between Russia and Transdniestria and statements of support from senior Russian politicians. However, the political situation was constantly evolving and it was difficult to give a comprehensive assessment. 3. The Russian Government (a) The jurisdiction of the Republic of Moldova 95. The Russian Government did not comment on the jurisdictional position of the Republic of Moldova in this case. (b) The jurisdiction of the Russian Federation 96. The Russian Government took issue with the Court’s approach to jurisdiction in Ilaşcu and Al-Skeini (both cited above). They contended that it was the will of the Contracting States, as expressed in the text of Article 1 of the Convention, that in the absence of an express declaration under Article 56 each State’s jurisdiction should be limited to its territorial borders. In the alternative, the approach followed by the Court in Banković and Others v. Belgium and 16 Other Contracting States (dec.) [GC], no. 52207/99, ECHR 2001-XII was a more accurate interpretation, since it recognised that jurisdiction could be extended extra-territorially only in exceptional cases. For the Russian Government, jurisdiction could exceptionally be extended extra-territorially where a Contracting state exercised effective control over another territory, equivalent to the degree of control exercised over its own territory in peacetime. This might include cases where the State Party was in long-term settled occupation or where a territory was effectively controlled by a government which was properly regarded as an organ of the relevant State Party, in accordance with the test applied by the International Court of Justice in the Case Concerning the Application of the Convention on the Prevention and Punishment of Genocide (Bosnia and Herzegovina v. Serbia and Montenegro (see paragraph 76 above). It could not be said that Russia exercised jurisdiction in the present case, where the territory was controlled by a de facto government which was not an organ or instrument of Russia. 97. In the further alternative, the Russian Government contended that the present case should be distinguished from previous cases because there was no evidence of any extra-territorial act by the Russian authorities. In contrast, in Al-Skeini, for example, the Court found that the applicants’ relatives fell within United Kingdom jurisdiction because they had been