The focus of Chapter 4 seeks to determine whether the dominant focus should be judicial or non-judicial. To that end, the manner in which the European Court of Human Rights has interpreted ‘jurisdiction’ under Article 1 of the ECHR in a representative sample of seminal cases pertaining to ‘grey zones’ is examined. The chapter highlights the inconsistency of Court practice, the manifestly inexecutable nature of many of the cases associated with grey zones and, consequently, the limits of the Court in affecting general or individual justice in practice in these regions. The chapter concludes by noting that effectiveness depends on looking beyond the Court.