Word of Life Armenia v Armenia - State Religious Neutrality

Word of Life Church of Christians of Evangelical Faith in Armenia and Simonyan v Armenia [2026] ECHR 57 was primarily about the role of domestic courts in upholding the State’s duty of neutrality and impartiality in religious matters.

Background

In 2011, the authorities investigated a man, K.A, for allegedly distributing pornographic material and violating privacy after he published intimate photos involving a well-known actress, A.S – an incident that sparked widespread public debate about the balance between protecting private life and regulating pornographic content [5]. There was intense media coverage, including unconfirmed speculation that A.S. belonged to Armenia’s biggest “sect”: Word of Life [6]. The newspaper Iravunk Hetaqnnutyun then published an article linking the scandal to Word of Life, claiming that A.S. was a member and accusing her of serious misconduct and alleging “that she had engaged in lewd acts with her own child” [6]. It also stated that Word of Life was a “sectarian union”, and that it exerted influence in certain circles involving television companies and public officials [6]. A similar article appeared shortly after in another newspaper, reinforcing these claims and suggesting that the Word of Life promoted questionable values. A.S. publicly denied ever being affiliated with the organisation [8], but despite that, further publications continued to target the applicants, using inflammatory language and encouraging public opposition to them. Finally, in November 2011, the applicants sued Iravunk Media Ltd, the publisher of the Iravunk Hetaqnnutyun and Argumenti Nedeli v Armenii newspapers, for defamation [10].

In July 2012, the District Court dismissed the claims, ruling that the publications had not contained defamatory or insulting statements and that were protected by the publisher’s right to freedom of expression, which allowed journalists to use exaggerated and provocative language. Further, the applicants had failed to prove defamatory intent on the part of the respondent. The District Court held in particular

“… that the articles and images were published only after the scandalous events involving the actress [A.S.], in which her name was linked to the [applicant] organisation, which was regarded as a sectarian organisation and was subjected to criticism. From the moment [the applicants] entered the arena of open public debate they needed to show a certain amount of tolerance towards criticism, which, taken as a whole, has [had] the nature of an open debate pursuing the aim of instilling society with certain religious ideas or of [preventing it from] deviating from the religious beliefs of the Armenian Apostolic Church, rather than the aim of insulting or defaming someone” [16].

On 8 November 2012, the Civil Court of Appeal dismissed their appeal and upheld the judgment of the District Court. As regards the applicants’ complaints about the use of the word “sect”, the Court of Appeal stated, in particular:

“… having examined the arguments raised in the appeal regarding the word ‘sect’ and its interpretations, ;;; even in their appeal the [applicants] did not deny the fact that their activity deviated from the beliefs of the Armenian Apostolic Church” [15].

In December 2012, the applicants appealed to the Court of Cassation but, in doing so, confused the dates of the two judgments, and in January 2013, the Court declared the appeal inadmissible on the ground that the judgment of the District Court was not amenable to appeal in cassation proceedings. In February 2013, the applicants resubmitted their appeal of December 2012, having amended the last paragraph to refer to the correct decision – that of the Civil Court of Appeal on 8 November 2012 – but the second application was ruled inadmissible as out of time [19-22].

Before the Fifth Section, the applicants contended that the Court of Cassation’s decision to declare their appeal on points of law inadmissible had breached their right of access to a court as provided in Article 6 ECHR [28] and that the District Court had violated the State’s duty of neutrality and impartiality in religious matters, contrary to Article 9, because of certain findings that it had reached when assessing the use of the words “sect” and “sectarian” in the newspaper articles [40].

The judgment

On the first ground, the Fifth Section held that the Court of Cassation must have known that the wording of the concluding part of the applicants’ appeal was the result of a typographical error or some similar oversight, and though it could have given the applicants an opportunity to correct their mistake it had chosen not to do so without giving any reasoning for its choice and had declared the appeal inadmissible without giving the applicants any further chance to remedy the situation. As a result of the Court of Cassation’s strict application of the procedural rules, their appeal on points of law was not examined on the merits [37]. Though the limitation applied by the Court of Cassation pursued the legitimate aim of ensuring the proper administration of justice, it had demonstrated “excessive formalism” by applying the rules in a particularly strict manner that disproportionately and unjustifiably restricted the applicants’ right of access to the court [38]. There had therefore been a violation of Article 6 § 1 [39].

As to the second ground, the Fifth Section said that its judgment was concerned solely with the applicants’ complaint that,

“… when performing the balancing exercise between the competing rights, the District Court itself committed certain acts which breached the guarantees of Article 9 … in particular, … the District Court’s finding that their religious activity deviated from the belief system of the Armenian Apostolic Church, the dominant church in Armenia, and that consequently it was acceptable to call the applicant organisation a ‘sect'”

and that, by doing so, the District Court had assessed the legitimacy of their faith and thereby breached the State’s duty of neutrality and impartiality in religious matters under Article 9 [51].

The Court reiterated that, provided that religious or philosophical views attained a certain level of cogency, seriousness, cohesion and importance, the State’s duty of neutrality and impartiality was ‘incompatible with any power on the State’s part to assess the legitimacy of religious beliefs or the ways in which those beliefs are expressed’ [52]. While the Court had no reason to doubt that the applicants’ beliefs passed that threshold, the domestic courts had not been in breach of their duties under Article 9;

“… it cannot be said that the domestic courts interfered with the applicants’ Article 9 rights. It is notable that the domestic courts did not themselves use the word “sect” in respect of the applicant organisation, or characterise it as such. Nor did the scope of their examination ever embrace any issue concerning the legitimacy of the applicants’ faith … the Court cannot agree with the applicants’ argument that, by stating that their religious beliefs differed from those of the Armenian Apostolic Church, the domestic courts delved into an assessment of the legitimacy of the applicants’ faith. In sum, no issue arises under Article 9 with respect to the complaint concerning the alleged breach of the State’s duty of neutrality and impartiality, as argued by the applicants” [53].

In brief, there had been a violation of Article 6, but there had been no violation of Article 9.

Cite this article as: Frank Cranmer, "Freedom of belief vs freedom of expression: Word of Life " in Law & Religion UK, 7 April 2026, https://lawandreligionuk.com/2026/04/07/freedom-of-belief-vs-freedom-of-expression-word-of-life/

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