Estemirova had clashed repeatedly with Chechen authorities. She had contributed heavily to recent human rights reports documenting the extrajudicial punishment and burning of homes of people related to suspected anti-Kadyrov rebels.
She had also contributed to a report released Wednesday that called for Russian officials, including Prime Minister Vladimir Putin, to be held accountable for human rights crimes.
"There's an atmosphere of impunity," Estemirova said in an interview last year. "We have a list of more than 4,000 people still missing and there are many cases in which we have hard evidence against people who kidnapped them, we even have their names and ranks, but it's impossible to initiate an investigation."
Earlier this month, she had publicized the case of a man who was shot to death in the streets of a Chechen village, without trial or investigation, for alleged ties to the rebels.
"The Chechen authorities immediately made it known . . . that Memorial should not air the household garbage in public like that," Cherkasov said.
In a sharp departure from the official reaction (or lack thereof) to the slayings of other critics, Russian President Dmitry Medvedev's office offered condolences to her family and said she probably had been killed for her human rights activities. Investigators were dispatched to the Caucasus to open an inquiry.
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megan.stack@latimes.com
Times staff writer Sergei L. Loiko contributed to this report.