A ruling that went into effect in January by the European Court of Human Rights halting all extraditions to China passed an important test earlier this month when the Italian Supreme Court overturned a decision to extradite a businesswoman to China.

The human rights court had determined that states that are party to the European Convention on Human Rights, which includes virtually all European nations except Russia and Belarus, cannot extradite people to China unless the Chinese government can demonstrate that the extradited person will not be tortured or be subject to inhuman and degrading treatment. This shuts down extraditions to a country that does not allow international scrutiny of its penitentiaries, underscoring international concern over the Chinese government’s widening dragnet that tries to bring home dissidents and critics living in exile.

But China still has the capability to tie down its citizens in lengthy legal battles by issuing Interpol red notices — an international alert that requests other countries find and arrest suspects who have fled abroad for extradition or other legal actions — while also deploying an array of illegal tools of repression. Despite Europe's attempt to close the door on China's extradition campaigns, Beijing has ratified a spate of new extradition treaties with countries outside of Europe.

In Liu v. Poland, the human rights court, which is based in Strasbourg, France, ruled that extraditing Hung Tao Liu, a Taiwanese man who had appealed his extradition from Poland, would place him at a significant risk of ill treatment and torture.