Background
In Figel’ v Slovakia [2025] ECHR Application no. 12131/21 Dr Ján Figel’, a former EU Commissioner and Special Envoy for Freedom of Religion or Belief outside the EU, challenged the total ban on religious services imposed by the Slovak Government in 2021 as part of its COVID-19 restrictions; in response, the Slovak Bishop’s Conference had suspended the holding of public religious services until further notice [1]. He complained that preventing him from attending public religious services had violated his rights under Article 9 of the Convention, that the interference in question had not been in accordance with the law, had not pursued a legitimate aim and had not been necessary in a democratic society [2]. As a practising Roman Catholic accustomed to attending religious services three times per week, he had been personally and directly affected by the contested measures because he was a Slovak national, lived within the jurisdiction of Slovakia and had not been able to attend public religious services [4].