This decision was handed down in the European Court of Human Rights on 11 March 2025 in an application made by Hayk Grigoryan (the “Applicant”) against the Republic of Armenia (the “Respondent”). The case concerned the alleged obstruction of the Applicants’ journalistic work while he was filming an alleged assault on a civilian by police officers. The Applicant relied on Article 10 of the Convention for the Protection of Human Rights and Fundamental Freedoms (the “Convention”), claiming there had been a violation of his right to freedom of expression.
In 2016, a group of armed men stormed the premises of the Patrol Service Regiment of the Armenian Police. Widespread protests followed, with the demand of the resignation of the then Armenian president. During those events, the Applicant was a freelance journalist and was covering one of the demonstrations which turned violent. He tried to film a group of police officers who were allegedly assaulting a demonstrator. The officers grabbed the Applicant, hit him, and seized his phone and camera. The camera was later returned to him, but his footage of the protests had been deleted.
The Respondent argued that, because the criminal investigation into the events was still ongoing, this application should be rejected as premature. As this criminal investigation had been pending for seven years without significant progress, the Court dismissed the Respondent’s objection.
The Court observed that, although the Applicant had not been wearing a press card, he had informed the police officers that he was a journalist at work, and they had acknowledged the Applicant was filming. It was clear from footage provided that the Applicant had sustained injuries resulting from the altercation with the police officers. Despite repeated requests, it had taken a considerable amount of time before the Applicants belongings were returned to him.
The Court found that the police officers had interfered with the Applicant’s work as a journalist. It was determined that the attack on the Applicant and the seizure of his equipment alone had significantly hindered his right to receive and impart information, and so it was not necessary to establish whether the footage had been deleted by the police officers. Such interference was not considered to have been “necessary in a democratic society”. Therefore, the Court held that Article 10 of the Convention had been violated.