Bulgaria's rape laws have been controversial, with a number of applications made to the European Court of Justice for breaches of the Convention on Human Rights. In M.C. v Bulgaria, the ECJ held that the decision not to prosecute the rape of a 14-year-old rape victim breached her rights provided under Articles 3 and 8.[30] The legislation enshrined a practice where rapes would only be prosecuted where there was evidence of physical force and active resistance. The court held that rape laws must apply to all forms of non-consensual sexual acts.