The following is our review of the primary and most representative events in the misuse of Russia's anti-extremist legislation in June 2024.

Lawmaking

On June 21, a group of parliamentarians led by deputy Alexander Khinshtein and senator Andrei Klishas introduced a bill in the State Duma. The bill proposes amending the law on countering extremist activities to include a ban on placing advertisements on the information resources of organizations, civic associations, or religious associations recognized as extremist. According to the proposal, the law on advertising should stipulate a ban on advertising on media resources of organizations recognized as extremist, terrorist, or undesirable. The explanatory note justifies the need for this law by highlighting that some Russian users continue to access information resources, such as Instagram and Facebook, via VPN, thus creating an opportunity for the owners of these resources to generate advertising revenue.

On June 26, a bill proposing amendments to the legislation on civic chambers and public control was submitted to the State Duma. Among other things, deputies want to amend the law “On Control Over Activities of Persons Under Foreign Influence” by banning foreign agents from joining public control institutions and carrying out activities related to public control. The institutions of public control institutions include civic chambers and community councils, and the corresponding activities encompass the work of public monitoring commissions (with NGOs designated as foreign agents barred from proposing candidates for such bodies since December 2022), civic inspections, groups, and other civic control structures. The proposal also adds the function of “preserving, strengthening and popularization of traditional Russian spiritual and moral values” to the mandate of civic chambers and civic control in general. In addition, not only individuals with dual citizenship but also legal residents of other countries will be banned from the Civic Chamber of Russia.

The Practice of the European Court of Human Rights

On June 4, the European Court of Human Rights (ECHR) published a ruling on the complaint of Ruslan Sokolovsky. In 2017, video blogger Ruslan Sokolovsky was issued a suspended sentence under Article 282 Part 1 (inciting hatred) and Article 148 Part 1 (public actions aimed at insulting the feelings of believers) of the Criminal Code (CC). He was later released from punishment due to partial decriminalization of Article 282 CC. Sokolovsky faced the charges of inciting hatred and insulting the feelings of believers for publishing videos with provocative statements that primarily advocated atheism, including the story about catching Pokémon in the Church of All Saints in Yekaterinburg (we discussed Sokolovsky's videos in more detail here). SOVA Center classified the prosecution of Sokolovsky under Article 282 CC, and Article 148 CC as inappropriate.

The complaint considered by the ECHR concerned a violation of Sokolovsky’s right to freedom of expression. The court found that the blogger’s rights guaranteed by Article 10 of the Convention for the Protection of Human Rights and Fundamental Freedoms were indeed violated. Overall, the Strasbourg court concluded that the blogger’s statements were never properly considered, especially in light of the criteria dictated by the Convention. The ECHR noted that the Russian courts based their decisions on the testimony of two prosecution witnesses and an expert opinion requested by the investigation, which is typical of Russian legal proceedings in similar cases. Moreover, the courts have focused on the offensive form of Sokolovsky's statements, ignoring their content, and made no attempt to establish whether they were, in fact, aimed at inciting hatred towards the church or believers of particular religious movements. According to the ECHR, Sokolovsky expressed his opinion on matters of public interest, choosing a harsh tone because he was targeting a youth audience. The following issues were not properly considered: whether the blogger's videos could pose any real danger to Russian society and whether there were any preconditions for such danger, for example, ongoing acute interreligious or interethnic conflicts that Sokolovsky could have exacerbated with his statements. Since the blogger did not call for illegal actions or violence, the danger of his statements was purely hypothetical. Therefore, restricting Sokolovsky's right to express his opinion was not necessary in a democratic society. The court stated that Russia must compensate him for moral damage in the amount equivalent to two thousand euros.

On June 25, the Grand Chamber of the ECHR issued a decision in a case combining two complaints filed by Ukraine in 2014 and 2018 about violations of the European Convention on Human Rights by Russia in Crimea. The ECHR indicated that, while exercising effective control over the territory of Crimea, Russia should, in accordance with the Fourth Geneva Convention, continue to apply the legal codes under which the local population lived previously. Specifically, the Crimean courts should have continued to apply “all Ukrainian legislation (civil and criminal) and not replace it with Russian legislation unless necessary.” The ECHR ruled that various administrative practices used by the Russian authorities in Crimea violated Articles 2, 3, 5, 6, 7, 8, 9, 10, 11, 14, Article 1 of Protocol 1 to the European Convention, and Article 2 of Protocol 1. The court also decided that “there has been a violation of Article 18 in conjunction with Articles 5, 6, 8, 10 and 11 of the Convention,” due to actions aimed at “punish and silence any political opposition.” This decision of the ECHR concerns many sanctions against Crimeans classified by SOVA as inappropriate – among others, the ban on the Mejlis, and the persecution of religious organizations and their members, including Jehovah's Witnesses and Hizb ut-Tahrir.

Sanctions for Anti-Government Statements and Activities

Calls for Terrorism

On June 3, the 1st Western District Military Court sentenced a resident of the Komi Republic, Artyom Maltsev, to a fine of 350 thousand rubles under Article 205.2 Part 2 CC (calls for terrorist activities on the Internet). The criminal charges against Maltsev were based on his VKontakte comments posted between April 2020 and January 2022. According to investigators, the defendant’s comments called for “carrying out terrorist activities by targeting the life of government members of the Russian Federation.” Maltsev called for “impaling on a stake” of Deputy Prime Minister Tatyana Golikova, State Duma deputies Valentina Tereshkova and Irina Yarovaya, as well as the Head of the Komi Republic, Vladimir Uyba. He told the court that he published such comments to express his negative attitude towards the current government that had imposed coronavirus restrictions. We do not know the exact content of these comments, however, if they contained only statements that called for impaling government officials on a stake, then we doubt the validity of the prosecution of Maltsev under Article 205.2 CC. In our opinion, the expression “impaled on a stake” should be interpreted figuratively, as dissatisfaction with the actions of government officials who introduced coronavirus restrictions and the desire to hold them accountable. Indeed, we are hardly talking about a serious call to apply a medieval execution method against officials.

On June 29, it became known that a criminal case under Article 205.2 Part 1 CC (public calls for terrorist activity) was opened against Georgy G., a resident of the North Ossetian village of Arkhonskaya. According to the ASTRA Telegram channel, the investigation claims that while voting in the presidential election in March 2024, the defendant spoiled the ballot, namely drew a hanged man, wrote the slogan “Glory to Ukraine” and wrote an obscenity in the line corresponding to the candidacy of Vladimir Putin. The investigation contended that Georgy G.’s actions incited “an indefinite circle of people” to hang the president and “forcibly change the government to serve the interests of Ukraine.” In our opinion, the hanged man drawn on a ballot along with statements indicating dissatisfaction with the president's political course does not provide grounds for criminal charges under the article on public calls for terrorist activity. Such charges are appropriate only if the call for such activity is clearly articulated, public, and poses a real danger of implementation. It is difficult to imagine a scenario in which a few election commission members, upon encountering such a drawing, would proceed to violently overthrow the regime in Russia.

It is important to note that in cases where charges are brought solely under Article 205.5 CC for participation in a terrorist organization, but there is no evidence that the defendant has committed or prepared to commit other terrorist or violent crimes, we classify such cases as inappropriate – in particular because the punishment is disproportionately severe given the circumstances. Two verdicts under this article issued in June once again demonstrated the unreasonable cruelty of such law enforcement.

On June 17, the 2nd Western District Military Court sentenced Ukrainian citizen Kristina Lyubashenko to 12 years in prison under Article 205.5 Part 2 CC (participating in the activities of a terrorist organization) and paragraphs “b” and “e” of Article 207.3 Part 2 CC (disseminating “fakes about the army” by a group of people motivated by political hatred). The case against Lyubashenko was based on two anti-war actions. On May 8, 2023, she placed a speaker on her window and played a recording of an anti-war address with the Ukrainian anthem in the background. For this, she was charged under Article 207.3 CC. Later, also on May 8, 2023, Lyubashenko went to Sparrow Hills (Vorobyovy gory) in Moscow and launched balloons with a white-blue-white flag attached to them. The investigators regard the flag as a symbol of the Freedom of Russia Legion, which is recognized as a terrorist organization. According to law enforcement officials, this action represented evidence of Lyubashenko’s participation in the Legion’s activities. As the defendant in the case herself stated, she carried out both actions at the request of a certain acquaintance, who introduced himself as a refugee from Ukraine. Lyubashenko met him after leaving Kyiv for Switzerland due to the special military operation. Her defense stated that, after moving to Switzerland, Lyubashenko did not have enough money to live and support her children, grandfather, and sick mother, so she agreed to go to Moscow and hold anti-war actions, first at the acquaintance’s request, and then under threats and pressure from him. We believe that even if the Ukrainian citizen launched a white-blue-white flag into the sky to promote the activities of the Freedom of Russia Legion, this act did not provide sufficient grounds for criminal prosecution. An administrative case under Article 20.3 Part 1 (public display of symbols of a banned organization) of the Code of Administrative Offenses (CAO) could have been opened instead. We also view the charge under Article 207.3 CC as inappropriate (see below for more information on this article).

On June 20, the 2nd Western District Military Court sentenced fifteen-year-old high school student Arseny Turbin from the city of Livny, Oryol region, to five years in a juvenile correctional facility, having found him guilty under Article 205.5 Part 2 CC. In the spring of 2023, then fourteen-year-old Turbin wrote to a bot channel in Telegram, which he believed to be the channel of the Freedom of Russia Legion. He expressed his desire to join the Legion and subsequently received an email address to continue correspondence. On June 1, Turbin wrote to this address expressing his interest in joining the movement. He stated that he was “ready to put up flyers and combat Putin's propaganda” and mentioned that he “has an idea about freeing Russia from Putin.” He was asked to send his contact information for messaging, which he did, and on June 6, he received a questionnaire for those wishing to join the Legion. According to the investigation, Turbin completed and submitted the questionnaire on June 7 “using an undetermined method.” However, he claims he never actually submitted it. According to the case file, on June 8, Turbin recorded a voice message to a friend stating that he had changed his mind about joining after watching a video in which the Legion promised to return Crimea to Ukraine. However, Turbin did not abandon the idea of distributing opposition leaflets. In June–July 2023, he printed out at least a hundred copies of a leaflet criticizing President Putin's political course found on the Internet and began distributing them to mailboxes. He filmed his actions with the help of a ten-year-old friend and posted the footage on his Telegram channel, which he named “Free Russia.” He also shared additional materials on the channel: “an audio recording of his monologue with a negative assessment of a group of people united by their affiliation with state and local government bodies as well as Putin V. V.”; a photographic image of “himself holding a leaflet in the form of a white-blue-white flag”; statements from the channels of Mikhail Khodorkovsky and the Freedom of Russia Legion, and other materials. The investigation argued, and the court agreed, that Turbin did join the Legion in early June 2023 and performed all further actions as part of his participation in this organization, recognized as terrorist in Russia. Meanwhile, according to Memorial's project in support of political prisoners, the case file contained no evidence that Turbin had been planning to go to Ukraine or carry out sabotage in Russia.

Inciting Hatred towards the Authorities and Their Supporters

In our opinion, at least four people were inappropriately fined in June under Article 20.3.1 CAO (incitement of hatred or enmity, as well as humiliation of human dignity) for critical statements against government officials, law enforcement agencies, and military personnel, not associated with calls for violence.

It was reported on June 3 that a criminal case under Article 282 CC (incitement of hatred or enmity, as well as humiliation of human dignity) had been opened in Moscow based on a conflict between a taxi driver and participants in the armed hostilities in Ukraine. The incident occurred on the night of June 2. According to the soldiers, after they began discussing the special military operation and the Crocus City Hall terrorist attack, the taxi driver made negative remarks about them. He then forced them to leave the car on the Moscow Automobile Ring Road and physically pulled one of them out of the vehicle. The passengers filmed the end of the conflict and shared the video with the media. Taxi driver Aipbek Latipov, a citizen of the Kyrgyz Republic, claims that the special military operation participants were drunk and rude to him. During the trip, they changed the payment method from a bank card to cash. Following this, the driver decided to cancel their ride and dropped them off in a pullout area on the Moscow Ring Road. According to Latipov, the servicemen then began shouting and pushing him, with one of them striking the taxi driver in the back. Eventually, as the media reported, other taxi drivers came to his aid. Latipov noted that his conflict with his passengers was not caused by their discussion of the terrorist attack. “They said that while they keep on fighting, people come here, make money and kill innocents,” he recounted. We believe that this incident provided no grounds for initiating a case under Article 282 CC. Regardless of the exact phrases used in the exchange between the taxi driver and his passengers, it was a private conversation, and Article 282 CC implies liability only for public statements. We also note that, in our opinion, military personnel are not a vulnerable social group that requires special protection from manifestations of hatred. It is worth reiterating that we advocate for removing the vague term “social group” from legal norms on incitement to hatred due to its overly broad interpretation.

In addition, four cases under Article 20.1 Part 3 CAO concerning “disrespect for authorities and society” were reported in June. Three individuals faced fines ranging from 30 to 35 thousand rubles for posts with rude criticism of the president and supporters of the annexation of Crimea. The penalty for the fourth defendant remains unknown.

Hooliganism Motivated by Hatred

On June 10, the Oktyabrsky District Court of Yekaterinburg sentenced Alexander Neustroev to three years in an open prison under paragraphs “a” and “b” of Article 213 Part 1 CC (hooliganism committed with threat of violence, motive of hatred towards social group). We don't know for sure which specific social group Neustroev was charged with inciting hatred against, but the investigation likely classified his actions as motivated by hatred towards Russian military personnel. In April 2023 he insulted a schoolchild whose father is a member of the Russian national guard involved in the special military operation in Ukraine. Neustroev also cursed at the boy, because his hat was decorated with the letter Z, a symbol of the special military operation. The prosecutor's office of the Sverdlovsk Region also wrote that the Yekaterinburg resident threatened the child. The entrance intercom camera, located near the scene of the incident, captured it on video. The recording was then distributed to local media and online communities. Neustroev was soon detained, and a report was filed against him under Article 20.1 Part 1 CAO (disorderly conduct, i.e. a violation of public order that expresses clear disrespect for society accompanied by obscene language in public places and offensive harassment of citizens), but the administrative proceedings were later terminated due to the initiation of a criminal hooliganism case. In August 2023, the Leninsky District Court of Yekaterinburg terminated the criminal case at the investigators’ request, imposing a fine of seven thousand rubles on Neustroev. However, the Prosecutor General's Office contested this decision. In February 2024, the case materials were resubmitted for reconsideration, but this time to the Oktyabrsky District Court rather than the Leninsky District Court. The jurisdiction was changed because the victim’s mother worked at the Leninsky Court of Yekaterinburg and resigned shortly after the criminal case against Neustroev was initiated. In our opinion, the charges against Neustroev under Article 213 CC are inappropriate. The Criminal Code defines hooliganism as a gross violation of public order expressing clear disrespect for society. In judicial practice, a gross violation of public order indicates actions that lead to the infringement upon the public right to work and leisure, the work of institutions, and so on. Neustroev’s action resulted in no such consequences. We believe that the law enforcement response in this case should have been limited to administrative sanctions.

Discrediting the Use of the Armed Forces or Activities of Government Agencies

According to the data of the State Automated System “Pravosudie,” as of July 14, at least 117 people were punished in June under Article 20.3.3 CAO for discrediting the use of armed forces and actions of government agencies abroad.

“Fakes about the Army” Motivated by Hatred

We consider criminal cases under paragraph “e” of Article 207.3 Part 2 CC (dissemination of knowingly false information about the use of the Russian army motivated by political hatred) inappropriate unless the incriminating statements contain incitement to violence.

Organized Anti-Government Activities

It was reported in June that on May 30, the Korenovsky District Court of Krasnodar Krai sentenced Valery Gusev, a student at the Faculty of Law of the Kuban State University, to a fine of 300 thousand rubles. He was found guilty of financing extremist activities (Article 282.3 Part 1 CC) for a transfer of one thousand rubles sent in August 2021 to the banned Anti-Corruption Foundation (FBK). According to the student, he transferred the money “without thinking” shortly after watching the video “We're Moving Forward and Need Your Help.”

On June 18, SOTAvision journalist Artyom Kriger was detained in Moscow. On the same day, the Basmanny District Court took him into custody on charges of participation in an extremist community (Article 282.1 Part 2 CC). According to the investigation, Kriger participated in activities of the FBK.

Bans against Organizations

On June 5, the Omsk Regional Court recognized the Omsk Civic Association (Omskoye grazhdanskoye obyedineniye, OGO) as an extremist organization and banned its activities in Russia. A prosecutor's office in the Omsk Region filed the corresponding claim in court on March 19. The OGO described itself as “an association of free citizens from Omsk. Its Telegram channel published news on various topics, including corruption in the Omsk Region, the special military operation in Ukraine, and instructions on human rights defense, such as how to request alternative civilian service. One of the association’s founders, activist Nikolai Rodkin, has left Russia. A criminal case against him was opened in August of the previous year under Article 282 Part 1 CC for “humiliating the dignity of a group of persons united by serving on the Supreme Court” (previously he was wrongfully fined under Article 20.3.1 CAO for harsh statements against the police).

The prosecutorial claims stated that the OGO pursued the goals of “changing the foundations of the constitutional system in the Russian Federation” and “forcibly changing the regime in the country.” Its activities were allegedly based on the “extremist ideology that consisted of inciting hatred and hostility towards representatives of government institutions.” To achieve its goals, the association held mass events, including events held without permits; thus, the “anti-Russian forces” could use it to change the regime in the country. In addition, the OGO allegedly continued the activities of Alexei Navalny “under the guise of ideas” of fighting corruption. Thus, the movement was de facto punished for anti-corruption investigations and political criticism. We consider the ban against the OGO inappropriate. We have no data to substantiate the allegations that OGO supporters intended to overthrow the Russian government by force or on their involvement in the systematic dissemination of calls for violence. In and of itself, organizing peaceful actions, even without official permits, cannot be interpreted as an attempt to forcibly change the regime and does not fall under the definition of extremist activity. Accusing the movement of “continuing the activities of oppositionist Navalny” merely because the OGO was investigating corruption in the Omsk Region and discussing regional issues seems untenable to us. Moreover, the opposition activities carried out by Alexei Navalny were also peaceful and not aimed at forcibly changing the regime.

On June 7, the Supreme Court upheld the claim of the Ministry of Justice and recognized the “Anti-Russian Separatist Movement” and its structural divisions as an extremist organization,” banning their activities on Russian territory. According to the Ministry of Justice, the Anti-Russian Separatist Movement is an international movement “to destroy the multinational unity and territorial integrity of Russia.” Specific structural units of the movement were not named. The claim of the Ministry of Justice has not been published, but presumably this is yet another “flexible” ban, i.e. a ban against a non-existent organization that allows for prosecuting a wide range of various activists and ordinary citizens in different regions of Russia. Such decisions include recognizing the AUE subculture and “international LGBT movement” as extremist organizations, as well as banning the “Columbine movement” as a terrorist organization. Obviously, there is no single organization called the “Anti-Russian Separatist Movement” and linked by a common structure. The Ministry of Justice is likely referring to a range of organizations and activist initiatives that advocate for the secession of various regions from Russia, as well as possibly regionalist movements. We believe that such a ban will affect not only separatists who advocate the secession of certain regions from Russia by military means but also those who conduct peaceful discussions about the status of a particular territory or even about expanding its rights, including cultural rights, as part of Russia. The charges against them can be administrative or criminal. In addition to Article 20.3.2 CAO and Articles 280.1 and 280.2 CC that stipulate responsibility specifically for incitement to actions aimed at violating the territorial integrity of Russia, recognizing the “Anti-Russian Separatist Movement” as an extremist organization allows prosecution under Article 20.3 CAO, as well as Articles 282.2, 282.3 and 282.4 CC.

In our opinion, restrictions are permissible only for calls for violent separatism; peaceful discussions about the status of a particular territory should not be limited.

Displaying Banned Symbols

In addition, last month we learned that, back on May 28, the Leninsky District Court of Krasnodar sentenced Vitaly Merzlyakov to six months in an open prison under Article 282.4 Part 1 CC (repeated public display of prohibited symbols). Merzlyakov previously faced administrative responsibility for displaying prohibited symbols. In July 2023, the Leninsky District Court placed him under arrest for 10 days for his “notification” sent to the Ministry of Justice Directorate for Krasnodar Krai. In it, he introduced himself as the head of the family-tribal community. Under the address, he added a seal with a symbol that law enforcement agencies found similar to Nazi symbols. Next, he filed an appeal in the Main Directorate of the Russian Ministry of Internal Affairs in Krasnodar Krai and enclosed four thread-stitched sheets with similar symbols. The investigation, and subsequently the court, believed that Merzlyakov understood that these images “would be publicly shown to an unlimited circle of people, employees of the Ministry of Internal Affairs, who, in fulfilling their official duties, must register and review this application with all its attachments. We doubt the validity of the case against the Krasnodar resident. We believe that the prohibited symbols were not publicly displayed, as only a limited number of people could see the images. Moreover, the symbol used by Merzlyakov was not described in detail. If the image in question is a version of the Kolovrat, it should be noted that this is a popular Slavic neo-pagan symbol, widely used in different variations and significantly different from the Nazi swastika.

Protecting Historical Memory and “Traditional Values”

“Rehabilitating Nazism”

In June, we recorded two verdicts issued under Article 354.1 CC on the rehabilitation of Nazism. Seven people became defendants in new cases under the same article.

Desecrating the National Flag

On June 7, a criminal case was opened in Balakovo, Saratov region, under Article 329 CC (desecration of the state flag of the Russian Federation) against a 27-year-old local resident. He was placed under travel restrictions. According to the police, he published on social media an image of the Russian flag with superimposed text containing a negative assessment of this flag. Experts who examined the image concluded that the post contained signs of desecrating the flag. In general, a state can establish liability, including criminal, for the desecration of its official symbols. However, we would like to reiterate that criminal prosecution is justified only for crimes that pose a significant danger to society. Therefore, we doubt its appropriateness in cases that involve no direct physical impact on a flag but only published images, especially not accompanied by calls for violence.

“Insulting the Feelings of Believers”

It was reported in June that on May 30, a magistrate in Ryazan sentenced Denis Bolokhnov to 150 hours of community service under Article 148 Part 1 CC (insulting the religious feelings of believers) for his comments with “negative assessment of the religious feelings of believers,” left under posts in a news community on social media. We do not have precise information on which statements were incriminated against Bolokhnov, but we found several comments he wrote in the “Ryazan” community on VKontakte in 2023. These comments contained abusive epithets directed at Jesus Christ but no incitement to hatred against followers of any religion that could fall under Article 20.3.1 CAO. If Bolokhnov’s other comments were similar to these, they, in our opinion, did not warrant administrative or criminal prosecution.

A 58-year-old “citizen of the USSR” from Khabarovsk Krai, sentenced on June 14 under several articles to eight years in a minimum-security penal colony (see above), faced sanctions under Article 148 Part 1 CC for his posts containing calls to “ignore traditional Christian values.

On June 19, a magistrate in St. Petersburg sentenced Daria Krichker, a tattoo artist from St. Petersburg to 60 hours of community service, having found her guilty under the same article. The case was based on a photograph depicting a tattoo “Jesus in the moment of orgasm,” created by Krichker, who later published the image on social networks. Representatives of the Orthodox movement Forty Forties (Sorok sorokov) filed a complaint. Krichker was found guilty of “photographing a bare shin” with a tattoo that included a cross with a crucified Christ, a pectoral cross, and a thorny plant branch, which was altered to make the sacred images appear obscene, and then distributing this photo via a Telegram channel. Citizen R. saw the image on Telegram, was offended, and experienced moral suffering.” We believe that Krichker had no intention of inciting religious hatred, since she didn’t accompany her post with any statements to that effect.

On the same day, June 19, another magistrate in St. Petersburg sentenced the owner of the S’aint bars, Sophie Noskova-Avramovich, to a fine of 30 thousand rubles under Article 148 Part 1 CC. The case was based on the design of her establishment on Rubinstein Street. This bar and her other bar on Zhukovsky Street were decorated in a style described as “pop-Catholicism.” In particular, the bars’ interior decoration and menus featured crosses, depictions of angels and saints, as well as references to the Bible, events of the Middle Ages, and the TV Show “The Young Pope.” After activists of the Russian Community (Russkaya Obschina), the Russian People’s Militia (Russkaya Narodnaya Druzhina) and the Imperial Legion (Impersky Legion), as well as MMA fighter Maxim Divnich disrupted a party in the bar on Rubinstein Street and called the police, a criminal case was opened. The court concurred with the investigation’s view that Noskova-Avramovich organized a public display of the bar’s interior design and menu to an indefinite audience. This, according to the court, constituted “clear disrespect for society” and “humiliated and offended the religious feelings of believing citizens,” including one individual, D., who, after viewing the design, experienced moral suffering. The use of religious attributes in the interior decoration and the menu was allegedly intended to “emphasize the philosophy of hedonism and relativism that is unacceptable from the Christian point of view.” It must be noted that Noskova-Avramovich clearly did not pursue the goal of inciting hatred, and only used Christian attributes and symbols to further her business. The Code of Administrative Offenses contains Article 5.26 Part 2, which provides punishment for “deliberate public desecration of religious or liturgical literature, objects of religious veneration, articles, marks or emblems relating to the world outlook symbols or their damage or destruction.” However, the charges against Noskova-Avramovich did not indicate any damage to the emblems, while the concept of “desecration has never been legally defined. Thus, we believe that law enforcement agencies had no reason to press any charges.

Persecution against Religious Organizations and Believers

Jehovah's Witnesses

In June, Jehovah's Witnesses continued to face prosecution on charges of involvement in the activities of local religious organizations that were deemed extremist and banned.