Law and Media: Content and Control

LAW AND MEDIA: CONTENT AND CONTROL— ANALYSE THE LEGAL BALANCE BETWEEN ECHR ARTICLE 10 AND THE FREEDOM OF THE MEDIA IN RELATION TO THE PRIVACY OF CELEBRITIES

Article 10 of ECHR

The Governments already signed up to the European Convention on Human Rights (ECHR) are legally committed to respect certain standards of behaviour. In present era of democracy, freedom of speech and media activities are to be taken into consideration in this law of ECHR. For making public opinion, it is needed for the authorities and media operations to make public opinion and their dealings with privacy of the public figures and celebrities[1]. In addition to that, these governments are also responsible for protecting freedoms and basic rights of ordinary people[2]. Diversified opinion can include both praise and criticise for making an opinion for the government and celebrities. In this particular context, Article 10 of the ECHR mainly provides the right to the freedom of information and expression. This article has also stated that there is freedom of speech, which should be offered to every individual. However, it can be commented that these responsibilities carry a proper sense of action, which is to be delivered as per the essential demand from situational aspects. Some legal regulations are essential for managing a democratic aspect of society. Public safety and territorial integrity can also be taken into consideration.  According to Article 10, everyone in the country has the right to freedom of expression. Article 10 of ECHR has proclaimed fundamental rights to the ordinary people and the media houses. Furthermore, it is also to be found that the media houses are permissible to collect data and information from different sources and distribute it to the public for making public statements on behalf of the ordinary citizen. This right mainly includes the frame of receiving any important ideas and information without any interference from the end of frontairs and public authorities[3]. Right to speak is an essential component for the people to make a proper analysis of the scopes and applicability of both the common people and media personnel to make a successful public opinion management. This public opinion and understandings are to be managed for gaining a high scope in opinion and community development. Planning of the media action and investigation can be based on the dealings of information sharing and operative closures for evaluating the scope of better outlook of public opinion. However, there is a thin demarcation between public opinion and celebrity opinion. Celebrities are liable to share their information for managing a sustainable image management in operational features. Therefore, it can also be commented as one of the noted balance keeping drive in society if Article 10 of ECHR can be implemented[4]. In addition to that this right also provides the freedom to hold their opinions. All these aspects are to be managed by including a highly successful media planning and operation. It is effective for the media officials to undertake the influence of the freedom of speech and freedom of media to explore news and make opinion according to that. Article 10 under the Human Rights Act 1998 of Europe provides the people with freedom to hold their opinions and express them freely through writing, any media such as television, internet or radio or verbally[5]. Communication channels are to be included for gaining a wide approach of understanding of suitable performance need and a vast scope of opportunity building. This is to be performed as per the instructions from the government authority to keep the balance of personal opinion and media interaction. This article is also able to protect people’s right to express their views even though those are offensive or unpopular to other people. In a democratic approach of government, authorities are liable to provide this right to express their thought through different medium of communication. On the contrary, Article 10 of ECHR is not considered as an absolute right. Instead of that the main purpose of Article 10 is to define the freedom of expression in a detailed manner to understand what types of interferences are justifiable under Article 10. There are certain layers of social administration where this article 10 is not applicable. Factors of these stages are; national security, territorial integrity, public safety, public disorder and crime[6]. In this way, it has been possible to set certain restrictions on the right for protecting privacy of people and national security[7]

It has been reported that, Article 10 is applicable to the cases where ideas or information disturb, offend and shock any population or sector[8]. It is understood that speech from people, especially those who have special influence on the society, can make a larger impact in both positive and negative aspect. It is essential for the media personnel to deal with the influences of statements. These statements are to made as per the influences on the society. Implications of media houses and planning can be included for making a strategic mixing for focuses and evaluations. For example, in the case of Lopes Gomes da Silva vs Portugal [2008], Article 10 was violated where Silva, manager of a daily newspaper, Público was convicted of libel[9]. In this case, the Court stated that freedom of expression is of particular importance for the press and hence the limits of acceptable criticism can be wider when the politician acts within public capacity.  Along with that, it is also noticed from Observer and The Guardian v United Kingdom [1991] case where MI5’s operation has been commented as unlawful[10]. However, later The Guardian has complained that their freedom of press has been hampered, according to article 10. From this context, it has been understood that the limits in the freedom of expression of the press or media changes as per the effects of any case on the public. These limits are to be understood by the public figures to make a statement on public and make an edit of the statement accordingly. Along with that, external market situations are to be managed for gaining a high scope of people and media attraction[11]. However, negative influences can hamper the image of celebrity and event market operation. This event market and glamour world is not sustainable and even more factorable[12]. Therefore, it is essential for the celebrities to deal with the analytical application for managing the influence on the market. Freedom of expression as per Article 10 of ECHR also includes freedom of the media for reporting court proceedings. Media houses are liable to make a statement to bring people under one roof to make a strategic decision regarding their implications and planned management strategy. In order to deal with the opinions posted by people, in both common and celebrities, proper understanding of the domestic and international situation before passing any comment. Along with that, impact of the comment in international sphere with media coverage and editing can also be taken here for the consideration. In Maria Alekhina and Others V. Russia, 2018[13], case, it is understood that the Article 10 of ECHR have also provided the media houses the freedom to cover art and politics. In case of a larger sphere of the society, it is to be understood that, both art and politics have major influences on the social sphere. On the contrary, this freedom is also restricted if it has any negative effect on other human rights including fair trial or privacy[14]. It is needed for the media houses to create public opinion for making a significant analysis for gaining a high and sceptical view of society. Planning this approach can be helpful for the government officials to deal with the analytical implications for making a successful deal to make people aware. Additionally, planning and operative balance checking to evaluate the impact of word and speech can also be associated with the scopes for managing sources of social balance.

Due to this reason, the courts need to balance the right of people to privacy with the media’s right for reporting any information. This information delivery system through the media should avoid bringing any sensitive information which can cause a major damage. It depends upon the sensible judgement of the media to focus on the news for avoiding any such controversies. In this particular context, it has been reported that the media has the freedom to legitimately publish the photographs and articles of celebrities without taking permission or approval from them. In this way, these media balance their rights to freedom of expression with the celebrities’ privacy rights[15]. This rule was given by the ECHR in its Article 10 to maintain legal balance between expression related freedom of media and human rights. The commitments of the European Union in respecting media pluralism and freedom and in freedom of expression allows media to receive, impart and share information without any interference of other public authority[16]. On the other hand, Article 10 of ECHR also provides freedom of information and freedom of reporting[17]. This report has also shown that, according to Article 10 of ECHR, there is a limit for the presses or media in publishing private information of people which are exclusively licensed. Hence, by obtaining licensing, celebrities can prevent any private information as per their preferences. Thus, Article 10 creates a bridge between the freedom of expression of the media and privacy of celebrities.   

  1. Freedom of Media

The freedom of media is protected by the guidelines of Article 10 of the ECHR and it is one of the main pillars of democratic security in Europe. For instance, in case of any war or conflict situations, one of the key roles and responsibilities of the media is to provide important information to the public on time[18]. Trustworthy information contributes to the protection of people. Media houses are commonly responsible for making a statement about the situations to make people aware of it. It is also needed for the planners and developers to meet the strategic approaches of development notion, planning and development. Operative sources are to be included for the news collection and make its successful distribution, are also two common responsibilities of the media houses. Hence, collecting and sharing important information that are helpful for public figures is a freedom of media. The European Council promotes an enabling environment for the freedom of expression by giving legal guarantees for diversity and independence of media in terms of media actors’ safety[19]. Due to this reason, aligning the freedom of expression and freedom of media, Article 10 of ECHR provides the rights to the media actors to express their views freely. Political views are to be expressed by both common people and media actors as per the situation and right. However, in Incal v. Turkey 1998 case, court announced that, restrictions and penalties are to be imposed as per the influence of their comment in media on common society[20]. Therefore, it is essential for the media houses, celebrities and other public figures to choose their words carefully while making a statement regarding any issue. Situational evaluation plays a major role behind the application of Article 10 of ECHR while making a comment on sensitive issues. Along with that, in Ceylan v. Turkey 2008 case, it is needed for the government officials to make a successful assessment about the comment wheather it is political or not. Along with that, many media houses are currently promoting a message to keep peaceful coexistence. Therefore, various media houses are conducting awareness campaign for making people aware about the activity of animal preservation.  As for this reason, one of the key responsibilities of the media is to share information about any occurrences, celebrities or other public figures by ensuring their privacy. On the other hand, it has also been reiterated by the Court that audio visual media has more powerful and effective effects on the public compared to printed media[21]. Taking it into consideration, several restrictions have been applied in the freedom of expression of the media in terms of protecting the privacy of celebrities and other involved people.

2. Maintaining legal balance

It is important to maintain a fair balance between the right of people to respect for private life as well as freedom of expression in the context of publications or media. In case of various operative features, it is seen that media houses are liable to keep an observation on the balance to keep both information sharing and freedom of speech. As per the Article of 10 of ECHR, it is essential for the media houses for managing the personal space of those celebreities and deal with them accordingly[22]. In order to manage the tracking and operational influences, various aspects of Article 10 like offering privacy to the people, can be taken into consideration. Taking it into consideration, the court shows that although the media or press must not overlap specific bounds, it is needed to protect rights and reputations of others[23]. Article 10 of ECHR includes freedom of speech and press at that context to not making any harm to anyone’s personal privacy. Therefore, it is needed for the operators to provide respect to the personal space of the people. On the other hand, In order to make a statement regarding any issues, media houses needed to choose the questions and words to those celebrities carefully. Thus, this right also covers the freedom of the media or press in terms of maintaining privacy of the celebrities[24]. In this particular context, protecting the privacy of celebrities is also important in the context of the freedom of media. However, in most of the cases, freedom of speech and media applications are to be analysed for making a contradictory approach while most of the incidents and media narratives make an adverse impact on the news portals. On the other hand, it is also found that most of the media houses make an unnecessary intervention on the life of public figures. It is common that most of the people are interested to know about the secrets of success and family life of their favourite celebrities. However, it can cause a major intervention on the people’s life through an unwanted approach. Disturbing celebrities into their private moments and holidays, which can induce a high threat regarding the application of Article 10, is also to be conducted by the media houses. However, it is significant duty of the media houses to collect proper data and information regarding the activities of the celebrities. Celebrities are not all those people who are associated with the gaming and entertainment world. This term can include politicians and business people of the society. It is not justified for the media personnel to intrude in those people’s life and it can often hamper their working.  Thus, this article becomes able to protect the rights of the media to criticise, value judgements or to make assumptions regarding celebrities and other people. On the contrary, it has been noticed that in some cases related to Article 10 of ECHR in defending where claim brought against the media for publishing any private information. For instance, in the case of Axel Springer AG v Germany [2008], the freedom of expression of the journalist was subject to his faith for providing precise and reliable information[25]. It further indicates that by maintaining privacy and confidentiality of the celebrities or any public figure, the media needs to hold and share their information and photographs as well. These photographs are to be managed in public posting that can make a negative image on the public domain. Article 10 has mentioned about the right of the people, which is needed to get expressed. As per the current status of democracy and the freedom of speech, it is permissible for the media houses to get expanded their views and approaches as per the current situation[26]. However, it can also be confronted as per the freedom of press, speech and expression. For example, following Article 10, Germany gave a greater right to the celebrities not to share their private photographs[27]. It is understood from this context that German authority provides significant focus on the well being and information sharing of their citizens for making an abrupt analysis of their implications of social life. However, it is also restricted in this country to inspect personal whereabouts of the celebrity and other people and make any news without informing them. However, this law is not permissible to the news extent where it deals with the any offense in society[28]. In this particular context, it has been reported that media have the right to publish photographs or stories of celebrities or well-known people when the media maintain a responsible balancing exercise with the consideration of specific privacy issues[29]. In case of German media, it is essential for the houses to keep a track of the information and make its actual inclusion into operational performances and dealings. This plan of action needs infusion of balance keeping between what to share and what not. As per the Article 10 of ECHR, many institutional objectives are needed to get followed by the operative forces for managing the balance of dialogue and communication[30]. From this perspective, it has been understood that the media has the right to share different information about celebrities and hence the celebrities need to publish their private information, stories or photographs accordingly. In case of making any propaganda, it is not needed for the media houses to conduct a cross check to understand the authenticity of the news. As per Article 10 of ECHR, it is needed for the media houses to share authentic information to the common people for making public opinion.

Apart from the offline media, Article 10 of ECHR is also applicable to the internet or online media. It has been noticed that although there are many benefits of internet-based media, these online media are associated with a number of dangers related to unlawful dangers such as hate speech, speech indicating violence, defamatory remarks and so on[31]. It is previously commented in this study that, one of the prime notions of the changes is to be managed for gaining a high notion of social opinion management. Media houses are liable for making a justified approach towards their analytical applications to clear the identifications of speech and their influence on civic society. However, this speech development and their expressions are to be managed through internet protocol and different social media portals through the approach of Article 10 of ECHR. Due to this reason, Article 10 is applied to this internet media for maintaining privacy of people. However, it is seen in present context that social media traits include attacks which can make an unlawful entry to privacy of common people as well as celebrities. Many of the celebrities manage their social media accounts to share their opinion and pictures with the common people[32]. It makes both positive and negative impact on the common people with their obligations to deliver an effective approach towards larger formation of opinion. In order to maintain the balance between the freedom of expression and privacy of the celebrities, the courts apply intense focus on different facts of the case. It is mainly considered by the courts that in the case of any interference in the freedom of expression, the right may entail different measures including condition, formality, penalty or restriction[33]. According to Bowman v. United Kingdom 1998 case, political organisations are liable to announce their agenda and political influences to common people. As per the Article 10 of ECHR, it is essential for the political influencers to make people aware of their political planning and point of view. However, radical approach of political views can influence a large amount of people towards a social calamity. Apart from that one of the most significant factors in determining whether freedom of expression prevails is an assessment of public interest[34]. Freedom can be expressed through the approach of responsibility of speaker which is to be planned for managing public opinion. From the end of media personal and celebrities, it is essential for the people to make a abrupt approach of opinion making and their establishing to deal with the official purposes of statement delivery system. This is to be planned by the media officials for gaining an approach of understanding towards information management system. This information management system through speech can be helpful for the society to deal with the analytical implications for gaining a large opinion management. From this news, it has become clear that the effect of the information sharing by the media on public interests has a significant relationship with the freedom of expression or privacy of the celebrities. Privacy management is essential for both the common people and celebrities. It is needed for the media houses to get understood the implicative understanding of the speech and its influences. In order to make a successful implication of the Article 10 of ECHR is needed for managing a high growth scope for information gathering from different sources. However, military operations are not taking into the consideration. For keeping their information secret, military information are not to be shared with the newspaper and common people. However, this rule cannot be applied to the information sharing regarding administrative and political aspects.  On the contrary, collecting information through hidden cameras in a public space, among public figures, breaches the rights described in Article 10 of ECHR. For example, in the case of Alpha Doryforiki Tileorasi Anonymi Etairia V. Greece [2010], three videos were captured by the media using hidden cameras which is a breach in Article 10’s guidelines[35]. It is essential for the media houses to gather secret information regarding the personal life of the celebrities and uses it to make their TRPs to increase their sales and news and tabloids. After observing the implication of political expression, for making people aware about their duties and responsibilities, it is needed for the democratic institutions to arrange polling system. At the time of their rallies, they have rights to protest against the unlawful practices of the opponents as per Article 10 of ECHR.  As this media’s activity negatively impacted the public figures, it is considered as a case of conflicting the Article 10 of ECHR. From this context, it has been understood that there are certain limitations in the process of collecting information. These limitations are to be managed for gaining a wider approach of process initiation to make the procurement policies of speech and publication through the media. It is previously discussed in this study that no information regarding sensitive issues are to be discussed. Regarding glamour world, some of the facts are to be hidden from the eyes of common people. It is needed for the media houses to get understood about the privacy of common people. These privacies are to be accepted by the common people as well as understood by media houses. Due to the use of hidden cameras in this case, the media was not able to maintain privacy and confidentiality of the celebrities and other present people. Due to this reason, the specific guidelines of Article 10 were not maintained which further affected public figures. Public figures are liable for making a successful approach of information sharing and management through their freedom of speech and expression. All these perceptions of freedom of speech and publications are to be expressed in recent era of communication and its application for the management of freedom of speech. This freedom of speech is to be practiced by the common people for making an analysis to deliver a wider approach of media operative. Media personals are liable to manage their operative sources to collect information from both the ethical and often unethical practices which can often hamper the privacy of the common people as well as celebrities of the society. It is essential for the operators to meet the strategic need of the social development[36]. Opinion making and management are essential for the developers of those media houses to make a significant development of their approaches for gaining a wide opportunity to have their freedom of speech. In order to avoid such issues, it is needed to always maintain legal balance between the freedom of expression and the guidelines of Article 10 under ECHR for maintaining the privacy of celebrities.

From the above discussions, it has been understood that the Article 10 of ECHR is one of the most important parts of human rights in European countries. Human rights officials of different organisations are making a strategic development and communication for a wide scope of their speech delivery and opinion management. Communication is an essential tool in recent era of development and management to make a significant opinion of the society with including both common people and the celebrities. In this regard, it is essential for the operational communication delivery to infuse a high scope for their analytical deals. Article 10 of ECHR, have been proclaimed for people to use their freedom of speech and offer independence to media houses for sharing their information with common people. This has also helped us to deal with the essential priorities of the society and time[37]. This speech delivery approach is an essential part of the democracy and it plays a major role in election. People are accountable to think the implications of these strata before polling their vote. Along with that, in case of creating media hypes, celebrities are also to be infused as per the Article 10 of ECHR. Making a statement on current issue from the end of any celebrity, it is needed for gaining a wide approach for making a development of people’s opinion as well as makes them influenced. The guidelines of this Article allow both online and offline media to hold or share information of public figures without any kind of interference of the public authorities. Analysing different aspects of this Article, it can be concluded that Article 10 gives the right to freedom of expression to the media with certain restrictions to ensure maintenance of security and privacy of the celebrities. It is to be understood for the media houses to make scope for the privacy of the celebrities. It is needed for the media houses to make a common agreement between those people to get a comment or bite in a relevant place[38]. Generally, everyone’s personal time and mood to be given priority as per the essential implication of their opinion management. All these aspects of personal implications are to be managed for gaining an opinion to deal with the Article 10 of ECHR commitment. All these applications of this act is to be imposed to both common people as well as celebrities. Due to this reason, it is important to know the guidelines of Article 10 properly by the media to maintain the legal balance between ECHR Article 10 and the freedom of the media in relation to the privacy of celebrities. This legal balance is to be followed as per the analytical information management to deal with the law balance and approaches. All these approaches are taken into consideration for the implications of planning and development for gaining a better output. However, opinions of the public figures matter to a vast amount of people. In different social media tools and platforms are to be managed for gaining a higher approach of communication. This communication planning is a newer trend to apply significant growth for dealing with the applications to motivate people. People’s motivation is to be managed for gaining motivation for the development of the society. Therefore, it is also essential for the media houses to maintain the decency of private time provision. These provisions are to be implemented for a high motivation for their people. The above-mentioned specific restrictions on the freedom of media or freedom of expressions are needed to be followed to maintain privacy of celebrities. All these aspects of specific legal implications are to be managed communication for the motivation as per the Article 10. In order to make a proper understanding of their approaches of freedom of speech and press, speech and press freedom have been implemented. However, it is the responsibility to media authority to manage the dignity of common people as well as celebrities.

Refrence List

Féret v. Belgium, no. 15615/07, § 63, 16 July 2009

Amnesty International UK, ‘What is the European Convention on Human Rights?’ <https://www.amnesty.org.uk/what-is-the-european-convention-on-human-rights> Accessed 11 July 2022

ECHR, ‘The Council of Europe: the only organisation of its kind’ <https://www.echr.coe.int/documents/pub_coe_teaching_resources_eng.pdf> Accessed 11 July 2022

Feldek v. Slovakia, no. 29032/95, § 83, ECHR 2001-VIII.

Mind, ‘Human Rights Act 1998’ <https://www.mind.org.uk/information-support/legal-rights/human-rights-act-1998/articles-8-9-10-12-14/> Accessed 12 July 2022

Ibid; Animal Defenders International v. the United Kingdom [GC], no. 48876/08, ECHR 2013 (extracts).

WUWR, ‘Celebrity Rights in the UK after the Human Rights Acts – CNS’ <https://wuwr.pl/prawo/article/download/10042/9378/> Accessed 8 July 2022

ECHR, ‘The Council of Europe: the only organisation of its kind’ <https://www.echr.coe.int/documents/pub_coe_teaching_resources_eng.pdf> Accessed 11 July 2022

Lopes Gomes da Silva v. Portugal [2008, <https://heinonline.org/HOL/LandingPage?handle=hein.journals/hurcd11&div=130&id=&page=> Accessed 11 July 2022

For further details see the research report Internet: case-law of the European Court of Human Rights

Times Newspapers Ltd, cited above §§ 27 and 45; M.L. and W.W. v. Germany, nos. 60798/10 and 65599/10, § 90, 28 June 2018.

On the principles related to the press and the Internet see, for instance, Stoll v. Switzerland [GC], no. 69698/01, § 104, CEDH 2007-V; Times Newspaper Ltd, cited above, §§ 42-47; Fatullayev v. Azerbaijan, no. 40984/07, §§ 94-95, 22 April 2010; Delfi AS, cited above, § 134; Ólafsson v. Iceland, no. 58493/13, §§ 53-57, 16 March 2017.

See, for instance, Renaud v. France, no. 13290/07, 25 February 2010; Tierbefreier e.V. v. Germany, no. 45192/09, § 56, 16 January 2014, and De Lesquen du Plessis-Casso v. France (no. 2), no. 34400/10, § 35, 30 January 2014. See also Delfi AS (cited above, § 113), where, in the context of the journalistic duties on the Internet, the Court held that the “duties and responsibilities” that are to be conferred on an Internet news portal for the purposes of Article 10 may differ to some degree from those of a traditional publisher, as regards third-party content.

[1]Mind, ‘Human Rights Act 1998’ <https://www.mind.org.uk/information-support/legal-rights/human-rights-act-1998/articles-8-9-10-12-14/> Accessed 12 July 2022

Pinsent Masons, ‘Reporting on celebrities’ private lives can be legitimate, European Court of Human Rights rules’ <https://www.pinsentmasons.com/out-law/news/reporting-on-celebrities-private-lives-can-be-legitimate-european-court-of-human-rights-rules> Accessed 9 July 2022

European commission, ‘Media freedom and pluralism, <https://digital-strategy.ec.europa.eu/en/policies/media-freedom> Accessed 9 July 2022

Penningtons Manches Cooper, ‘I’M A CELEBRITY, BUT DON’T GET MY PRIVATE INFORMATION OUT OF HERE! (PART 1)” <https://www.penningtonslaw.com/news-publications/latest-news/2019/i-m-a-celebrity-but-don-t-get-my-private-information-out-of-here-part-1> Accessed 9 July 2022

Council of Europe, ‘Freedom of expression in times of conflict’ <https://www.coe.int/en/web/freedom-expression/media#:~:text=The%20right%20to%20freedom%20of%

20expression%20and%20freedom%20of%20the,of%20democratic%20security%20in%20Europe.>

Alpha Doryforiki Tileorasi Anonymi Etairia V. Greece [2010] <https://hudoc.echr.coe.int/eng#{%22itemid%22:[%22001-181295%22]}> Accessed 8 July 2022

United Nations Human Rights Council, The promotion, protection and enjoyment of human rights on the Internet, A/HRC/RES/20/8, 5 July 2012.

ECHR, ‘Guide on Article 10 of the European Convention on Human Rights’ <https://www.echr.coe.int/documents/guide_art_10_eng.pdf> Accessed 12 July 2022

Editorial Board of Pravoye Delo and Shtekel v. Ukraine, no. 33014/05, § 63, ECHR 2011 (extracts); Cicad v. Switzerland, no. 17676/09, § 59, 7 June 2016.

ECHR, ‘Guide on Article 10 of the European Convention on Human Rights’ <https://www.echr.coe.int/documents/guide_art_10_eng.pdf> Accessed 12 July 2022

ECHR, ‘The Council of Europe: the only organisation of its kind’ <https://www.echr.coe.int/documents/pub_coe_teaching_resources_eng.pdf> Accessed 11 July 2022

AXEL SPRINGER AG v. GERMANY [2008] <https://hudoc.echr.coe.int/fre#{%22itemid%22: [%22001-109034%22]> Accessed 9 July 2022

For the general principles on Article 3 of Protocol No. 1 see, for instance, Davydov and Others v. Russia, no. 75947/11, §§ 271-277, 30 May 2017.

ECHR, ‘The Council of Europe: the only organisation of its kind’ <https://www.echr.coe.int/documents/pub_coe_teaching_resources_eng.pdf> Accessed 11 July 2022

See, most recently, Moohan and Gillon v. the United Kingdom (dec.), nos. 22962/15 and 23345/15, 13 June 2017; Cumhuriyet Halk Partisi v. Turkey (dec.), no. 48818/17, 21 November 2017

The Guardian, ‘Media interest in celebrities’ lives is legitimate, European court rules’ <https://www.theguardian.com/media/2012/feb/07/media-interest-celebrities-european-court> Accessed 11 July 2022

See further the EU study on Referendums on EU Matters (PE 571.402, January 2017). Available at: http://www.europarl.europa.eu/RegData/etudes/STUD/2017/571402/IPOL_STU(2017)57 1402_EN.pdf.

ECHR, ‘Guide on Article 10 of the European Convention on Human Rights’ <https://www.echr.coe.int/documents/guide_art_10_eng.pdf> Accessed 12 July 2022

See also Öztürk v. Turkey, cited above, § 49; Editions Plon v. France, no. 58148/00, § 22, ECHR 2004‑IV.

ECHR, ‘Guide on Article 10 of the European Convention on Human Rights’ <https://www.echr.coe.int/documents/guide_art_10_eng.pdf> Accessed 12 July 2022

AXEL SPRINGER AG v. GERMANY [2008] <https://hudoc.echr.coe.int/fre#{%22itemid%22: [%22001-109034%22]> Accessed 9 July 2022

COE. ‘A Guide to the Interpretation and Meaning of Article 10 of the European Convention on Human Rights’ <https://rm.coe.int/16806f5bb3> Accessed 8 July 2022

See, for instance, Féret, cited above, § 59; Willem, cited above, § 29; Fatullayev, cited above, 79; PETA Deutschland, cited above, § 44; Tierbefreier e.V., cited above, § 49.

The Court reached the same conclusion, without extensive elaboration, in TV Vest AS and Rogaland Pensjonistparti, cited above, § 29

Ahmed and Others v. the United Kingdom, 2 September 1998, §§ 52-54, Reports of Judgments and Decisions 1998-VI.

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