European Interreligious Forum For Religious Freedom

Council of Europe Briefing

Written the Thursday, April 24th 2014 à 20:34

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An attempted strike against minority religions fails. Instead, a landmark victory for freedom of religion or belief


The European Interreligious Forum for Religious Freedom and the All Faiths Network coordinated extensively together, working with many other concerned groups and Parliamentarians to assist in dealing with this issue. We are joining together in this newsletter to provide a detailed account and explanation of what occurred.
On April 10, 2014 the Parliamentary Assembly of the Council of Europe voted down restrictive measures proposed by French MP Rudy Salles, in what has already been described as a “decisive victory and protection for human rights and religious freedom, which was made possible because of the thousands who stood up and voiced their opposition in a critical time of need” which “Historians of European religious liberty will look back at (…) and recognize it as a defining and progressive case study in the prevention of human rights abuse.”(1)
Here is a summary of what happened, including a perspective on the ideological background of those pushing what could have been a major step backwards for religious tolerance and the rights of religious minorities in the 47 countries that comprise the Council of Europe. 
It is also important to mention those in the Parliamentary Assembly who stood up against the report and we will provide extracts of their statements. 
On 7th September 2011, Rudy Salles, a member of the French National Assembly and also member of the Parliamentary Assembly of Council of Europe (PACE), was appointed at PACE as Rapporteur to draft a report on the “protection of minors against sectarian influence”. This has been a long-standing issue pushed by the French “anti-minority religions” groups. Rudy Salles is a long-time associate of Georges Fenech (2), member of the French National Assembly and former the head of the MIVILUDES (Inter Ministerial Mission for the Vigilance and Fight Against Sectarian Deviances), a French government agency in charge of fighting against what they call “sects”. When Salles’ appointment as rapporteur occurred, Georges Fenech made a joint statement with Rudy Salles in a French newspaper (Nice Matin, November 22, 2011), announcing the appointment and claiming that the purpose of that nomination was to create a European observatory on so-called “sects”, a sort of European MIVILUDES.

Georges Fenech - France
Georges Fenech - France
French “anti-sect” agencies have been pushing for a “European Observatory” for many years (3) and failed to make it happen, due to the absence of any real problems on this issue, either in France or in other EU countries. Governments are broadly aware of the fact that common criminal law can take care of any of the few cases related to so-called “sects”, and that it would be worthless to invest money and energy on a “non” problem.
In 2006, Georges Fenech, who was a Member of the French National Assembly at the time, presided over a Parliamentary Enquiry Commission on “children and cults”. The Commission interrogated dozens of members of government agencies, and the answers were uniformly that there were only very few or no cases related to “sectarian movements” reported by each branch of the different Ministries of the French government (4). The Parliamentary Commission was a failure from the perspective of Fenech and the results were unable to justify any further action, despite completely false and ungrounded statements from him stating that 60,000 children were in danger in “cults”. 
In the MIVILUDES 2009 report, Georges Fenech, as President of the MIVILUDES, carried out a full review of problems that might have occurred in EU countries regarding children and so-called “sects”. 
Unfortunately for him, the result of the review made it clear that no real problem existed in Europe on this subject. For example, the review of UK is covered in the report in the following way (5): “The cult phenomenon has little impact on youth in the United Kingdom. Only a few cases have been reported”. For Germany: “According to the Ministry of Family Affairs, Senior Citizens, Women and Youth, which coordinates interdepartmental work on issues related to sectarianism in Germany, the report of the "Bundeskriminalamt" ("BKA") on the disappearances of individuals contains no reference to the cult phenomena that are the cause of wrongful removal of children.” Regarding Czech Republic, only five reports were identified by MIVILUDES over the past 20 years. Regarding Portugal:  “This country does not identify any criminal activity involving a sectarian movement.” Regarding Netherland: "Activities of movements and practices with a risk of sectarian deviance is not considered a threat in itself in the Netherlands and does not constitute the subject of any specific public policy." (…) "According to the "Council of Child Welfare" and the Department of Justice, the phenomenon of sectarianism is not subject to any registration or reporting especially in the area of child protection". Regarding Greece: "There are also no recent incidents in the matter of children in Greece." Ireland: "The competent Irish services in the field of sectarian influences on youth are the Central Authority in relation to child abduction under the Ministry of Justice, and the office of the Minister for Children and Youth. These two services could not cite any recent case of wrongful removal of children linked to sectarian movements or any case of sectarianism concerning children.” Romania: "Similarly, the specialized services of these departments have not been confronted with sectarian deviances related to children.” For Poland: "The relevant departments in Poland, including the Prosecutor's Office, reported no recent case of sectarianism concerning children.” In Lithuania, no reports regarding sectarian cases: "In addition, the French notion of "sectarian deviance" is foreign to the Lithuanian approach regarding movements or religious groups which are all listed in the Department of Justice." Regarding Italy: "No specific information regarding sects affecting minors can be reported during the past year, whether from the Ministry of the Interior or from the Ministry of Social Affairs.” Regarding Finland: "The different movements which are also considered as a risk that are present in Finland, do not report abuses involving children or youth.” Regarding Latvia, Albania and Malta, "The embassies had no knowledge of missing children, parental conflict regarding the placement of children in sectarian organizations or sectarian deviances concerning children.” In Luxembourg, "The Department of Justice indicates that the Prosecutor General's Office reported no domestic case of wrongful removal of children in connection with sectarian movements and no special consideration was currently underway at the Department of Justice on the issue of sectarian aberrations affecting minors.”
This illustrates the fact that the subject of children and so-called “sects” was not a real issue. However, faced with the option of having no further justification for their activism in France, French anti-sect groups have pushed the idea that an observatory of cults was needed at European level. This has been announced many times by Georges Fenech, former President of the French MIVILUDES and the appointment of Rudy Salles, as rapporteur on the issue at Council of Europe, was celebrated as a “victory” for them.

Rudy Salles - France
Rudy Salles - France
For French anti-sect agencies, the idea of finding a way to gain a foothold in European institutions has been going on for some time. In 2008, at a FECRIS conference (FECRIS is a European “anti-sect” association, funded solely by the French government) at Pisa, Italy, Catherine Katz, at the time Secretary General of Miviludes, explained: “For many years, the MILS [predecessor of the MIVILUDES], then the MIVILUDES really wanted to show other European States in particular, that they were not, what the cultic movements and their friends alleged, attacking freedom of conscience and beliefs.”(…) “Now, it is useful to explain France’s position, it is also good to inform on the position of FECRIS, it is positive to communicate on the legitimacy of our action but can we go further? Can one imagine a common model in Europe and a minimum point of convergence? I tend to think that this could be realised only through technical actions and aspects, like problems of minors for example. Once again I am personally attached to the protection of the weakest and the protection of minors is a subject common to all and which could be a point of entrance. Which country can accept that its minors be crushed, destroyed, violated, misused? Another possible entrance point is health. An evaluation of deviating methods, be they cultic or not, can make it possible to find common ground. Why not a European observatory in the field of sectarian aberrations?” This is why they decided to take issue with the subject of “sects and children”(6)
Ideological background and FECRIS
The French anti-minority religious activists have for a long been active on the subject of children, with two main notions. The first notion is that minority religious beliefs are dangerous for children and should be fought against. The second notion is that followers of denominations labelled as “sectarian” should be considered as civilly incompetent and should be deprived of their children’s custody.
One illustration of these notions and their effect in France is that of Richard Dray: 
On the 15th April 2013, the newspaper “La Dépêche” told the story of a father who was forbidden to see his son solely because of his religious beliefs. The father, Richard Dray was 45 years old and an Orthodox Jew. After divorcing, Richard Dray had custody of his 12-year-old son at weekends.  The son started to have behavioural problems and was sent to psychologists for further evaluation. They in turn decided to place him in an institution. Richard asked for his son to be placed in a private institution and went before a judge to request this, who, seeing him with his kippah and his long beard, decided to remove his parental authority altogether, stating: “If you want to live like that, go live in Jerusalem.”
Richard still retained a right of access to his son. However, the social services placed the child in a home without telling the father where he was located. Eventually the father found out where he had been placed and called the institution to talk to his son. The son told his father over phone that he missed him and was sad. The father answered “do not worry, everything that happens to us on earth is a test sent by God that must be overcome”. The social services, who were listening to the conversation, then forbade the father to approach his son because of these so-called “fundamentalists words”, adding that he should not talk about God in 2013 to a 12 year old child and that it was contrary to their educational principles. 
This example illustrates the degree to which the social and judicial fabric in France has been overtaken by the above notions. These concepts have, through the last 15 or more years, gradually infiltrated into many spheres of French government at national, regional and local level. This has been done through the implementation of directives within different ministries, the “education” of judges, teachers and administrators as well as a discriminatory media climate that has been built up to stigmatize and isolate religious minorities.

Alexander Dvorkin - Russian Federation
Alexander Dvorkin - Russian Federation
At the level of the Council of Europe, the main lobby behind attempts to attack minority religions is FECRIS (European Federation of Centres of Research and Information on Cults and Sects), an umbrella organization that pretends to defend victims of sect excesses in more than 30 countries to date, among them 5 are non-European. While pretending to be politically, philosophically and religiously neutral, FECRIS, throughout many years, has been targeting minority faiths with hate speech on a regular basis, whether they be Christians, Hassidic Jews, Muslims, Buddhists, Hindus or new religious movements.
For example, the Vice President of FECRIS, Alexander Dvorkin, a Russian citizen who is actively involved with the Russian Orthodox Church, was hired by the Department for Religious Education and Catechism of the Moscow Patriarchate to address the problem of “sects” surging into Russia. He publicly declared: “We won’t be mistaken if we say that, from the Orthodox viewpoint, Krishna is one of the demons”(7).  He also declared: “The Christian Orthodox faith is the original (…) a sect is a fake, something forged, something tawdry”(8), and he attacked the Muslim faith in a number of statements saying things such as: “Either Mohammed suffered from a disease and it was a delirium vision; or it was demonic obsession”(9).
Roger Ikor, founder of the CCMM (Centre Against Mental Manipulation), one of the founding member of the FECRIS, went so far as to say: “Should we follow our inclination, we would put an end to all this nonsense, that of the cults as well as that of the great religions.”(10) 
FECRIS pretends to have presence in more than 30 countries to date. In fact, in most of these countries, FECRIS is only represented by very small associations, sometimes with only 2 or 3 members. Non European Union countries include Russia with the St. Irenaeus of Lyons Religious Studies Research Centre, founded in 1993 with the blessing of the Patriarch of Moscow and All Russia Alexy II, and directed by Alexander Dvorkin, as well as Israel with ICVC (Israel Centre for Victim of Cults).
While pretending to be an NGO, FECRIS is almost entirely funded by the French Prime Minister’s office. From 2001 to 2011, French government funding represented 92.27% of its funding. It’s what is called a GONGO, a coined humoristic term in UN lingo which means “Governmental Organization Non-Governmental Organization”.
FECRIS has regularly being criticized by human rights experts (11) for their use of hate speech and their spread of intolerance in society against minority religions.

The outcry
On March 3, 2014 the report drafted by Rudy Salles (12) was made public, as it was put on the PACE agenda for voting on the 10th of April during the plenary session. The draft report proposed a resolution and a recommendation, both were proposing to export the French model and policies to European level and to the 47 countries of the Council of Europe.
In reaction, more than 80 NGOs, from all over the world, wrote letters to the President and Secretary General of the PACE, as well as to individual members of the Parliamentary Assembly in order to protest against the very anti-religious French offensive at European level. As stated in the Council of Europe Human Rights blog  (13):
“Readers will remember that Israeli President Simon Peres, Turkey’s Deputy Prime Minister and many others were outraged by an assembly resolution last year which they thought threatened the ancient practice of male circumcision.
The assembly deftly rebuffed the criticism and faint whispers of anti-Semitism, claiming it only wished to start a dialogue.
Now, in a capital letter-headlined article published by World Religion News, the assembly has been warned that the new debate it has opened on ‘sect observatories’ has stoked the ire of yet more religious groups.”
Protesters included Dr. Aaron Rhodes, former Executive Director of the International Helsinki Committee, Co-Founder of the Freedom Rights Project, and current President of the Forum for Religious Freedom - Europe (FOREF(14); Vincent Berger, former Jurisconsult of the European Court of Human Rights (15) and Law Professor at the College of Europe (16); the famous Moscow Helsinki Foundation (17); the Union of Councils for Jews in the Former Soviet Union; as well as dozens of other organizations representing views from a very large section of society, from atheists’ and secularists to religious faith based organizations.
Several violations of internationally recognized human rights standards were pointed out in the Rudy Salles report and recommendations by legal experts, including the use of the words “sects” and “cults”, the use of which had been recognized as discriminatory and pejorative and not to be used by international and European human rights governmental institutions (18). 
One week before the plenary session, an online petition was been posted online to “stop proposed legislation in Council of Europe that poses a serious threat to religious freedom”(19). The petition gathered more than 12 000 signatures in a week.

Valeriu Ghiletchi - Moldova
Valeriu Ghiletchi - Moldova
The outcome
On April 10, 2014 after a heated debate during which Rudy Salles was supported mainly by French colleagues, the Parliamentary Assembly decided to uphold the international human rights standards with regards to freedom of religion or belief.
Mr. Ghiletchi (Moldova), a strong opponent of the report and, frustrated at Mr. Salles’ refusal to accept that there was no legal definition for the word sect and that it was used pejoratively to target religious minorities at one point stated, “I belong to a religious minority, and the whole time I was in the Soviet Union I was told that I belonged to a sect. I regret that today we will produce such a recommendation. I call on members of this Assembly who do not want to endanger people to reject the recommendation. We must not produce something that attacks people for their religious convictions. This is very sad.” 
Fortunatley, all Rudy Salles´ recommendations - identified by Dr. Aaron Rhodes as “a recipe for discrimination and intolerance” and something that would “provide cover for arbitrary interference in religious life” - were cancelled. Instead, a completely different proposal was adopted which stated: 
“The Assembly therefore calls on the member states to sign and/or ratify the relevant Council of Europe conventions on child protection and welfare if they have not already done so”.
Salles´ proposals to establish information centres, create “databases” for so called “sects”, establish a European observatory, carry out specialist training, create special laws for ”sects” covering an undefined “crime” of “mental manipulation” (20) and a range of other actions on groups he derogatorily called “sects” – were all rejected by the Parliamentary Assembly. 

Brian Binley - UK
Brian Binley - UK
Mr. Binley and Lord Anderston, both from the UK delegation, were also resolute in defending the principles of religious freedom. Mr. Binley pointed out that the draft resolution and recommendations, “violates the state’s duty of neutrality in matters of religion and belief, in that it focuses exclusively on selective and biased information from sources that support repressive action against minority religions. It infringes on fundamental freedoms and stimulates hostility against targeted groups.”

Lord Anderson - UK
Lord Anderson - UK
Lord Anderson called for reason when speaking in the debate, “Even our French colleagues are unable to define their target: sects. The word “cults” would run into the same problem in our language. They do not know what sects are. What they have said implies that they accept that the evidence is weak. To avoid any arrogance, why not turn to the wealth of academic and legal experts, who can help us define and co-operate in this field?”

Morten Wold - Norway
Morten Wold - Norway
The other key speaker against the report, Norwegian MP Mr Wold told the Assembly: "The report seems to have been written with the aim of protecting children and young people. However, it includes measures from France that although not discriminatory have had serious consequences for French minority families. I really do not think we want the same sorts of conditions in other Assembly member states. I also have to mention that the report is authored by our colleague Mr Salles, who works on an official basis with anti-religious groups such as Miviludes, a fact that he himself has confirmed to the media.”
By the end of the debate the Assembly issued an amended resolution requesting the Member States to implement policies of non-discrimination between traditional, non-traditional, new religious movements and “sects”, as can be seen in point 9 of the final resolution: 
9. The Assembly calls on member States to ensure that no discrimination is allowed on the basis of which movement is considered as a sect or not, that no distinction is made between traditional religions and non-traditional religious movements, new religious movements or “sects” when it comes to the application of civil and criminal law, and that each measure which is taken towards non-traditional religious movements, new religious movements or “sects” is aligned with human rights standards as laid down by the European Convention on Human Rights and other relevant instruments protecting the dignity inherent to all human beings and their equal and inalienable rights.
After having discussed the fact that no evidence could be found that would show that religious minorities, even when derogatorily and unduly called “sects” by some States, had been found guilty of crimes against children in a greater proportion than traditional or established religions or even the general population, the Assembly also adopted the following principle in point 5 of the resolution: 
The Assembly believes that any religious or quasi-religious organisation should be accountable in the public sphere for any contraventions of the criminal law and welcomes announcements by established religious organisations that reports of child abuse within those organisations should be reported for investigation to the police. The Assembly does not believe that there are any grounds for discriminating between established and other religions, including minority religions and faiths, in the application of these principles.
The Assembly rejected all the recommendations proposed by Mr. Salles.
This episode has been a great victory for religious freedom and against bigotry, and an extreme failure for anti-religious groups such as FECRIS who were attempting to impose the French anti-minority religious model throughout Europe. 
In crushing the dangerous expectations of FECRIS’ and Rudy Salles’ aficionados, choosing to adhere to freedom of religion or belief human rights standards, the Parliamentary Assembly of the Council of Europe upheld its longstanding commitment to human rights and remained consistent with its own standards as well as those of all human rights institutions around the world.
Addendum on the word “sect”:
It can be noted that the final resolution continues to use the word “sect”. This anomaly is at odds with the wording of the rest of the resolution, as it was amended, and can be put down to political trade-offs that are almost inevitable in a debate of this kind. However, the UN rapporteur on freedom of religion has clearly stated that use of the word sect was unacceptable:
In 1996, in his Annual Report, the UN Special Rapporteur on Religious Freedom noted the inadequacy of labelling certain belief groups as “sects”:
The term “sect” seems to have a pejorative connotation. A sect is considered to be different from a religion, and thus not entitled to the same protection. This kind of approach is indicative of a propensity to lump things together, to discriminate and to exclude, which is hard to justify and harder still to excuse, so injurious is it to religious freedom.
In its General Comment No 22 on the interpretation to be given to Article 18 of the ICCPR on the Right to Freedom of Thought, Conscience and Religion, the UN Human Rights Committee stated:
Article 18 protects theistic, non-theistic and atheistic beliefs, as well as the right not to profess any religion or belief. The terms “belief” and “religion” are to be broadly construed. Article 18 is not limited in its application to traditional religions or to religions and beliefs with institutional characteristics or practices analogous to those of traditional religions. The Committee therefore views with concern any tendency to discriminate against any religion or belief for any reason, including the fact that they are newly established, or represent religious minorities that may be the subject of hostility on the part of a predominant religious community.
Furthermore, the OSCE Guidelines for Review of Legislation Pertaining to Religion or Belief (21) laid out by the expert panel on religious freedom of the ODIHR and the Venice Commission (which is an expert legal body of the Council of Europe) it is written: 
2. The definition of “religion.” Legislation often includes the understandable attempt to define “religion” or related terms (“sects”, “cults”, “traditional religion”, etc.). There is no generally accepted definition for such terms in international law, and many States have had difficulty defining these terms. It has been argued that such terms cannot be defined in a legal sense because of the inherent ambiguity of the concept of religion. A common definitional mistake is to require that a belief in God be necessary for some- thing to be considered a religion. The most obvious counterexamples are classical Buddhism, which is not theistic, and Hinduism, which is polytheistic. In addition, terms such as “sect” and “cult” are frequently employed in a pejorative rather than analytic way. To the extent that legislation includes definitions, the text should be reviewed carefully to ensure that they are not discriminatory and that they do not prejudge some religions or fundamental beliefs at the expense of others. 
There is a rather tortuous reasoning in Salles’ attempt to impose the word “sect” throughout his draft report and resolution/recommendation. The use of the word is his cornerstone which attempts to drive a wedge between what would be arbitrary determinations of acceptable and unacceptable religion. He insisted on the use of this word throughout the debate claiming that ‘everyone knows what a sect is’ whilst at the same time writing in his report that “A number of studies have demonstrated that it is impossible to reach a consensus on the definition of ‘sect’.” (point 5) 
Moreover, Salles states, it is clear that a sect is a religious minority as opposed to a “traditional” religion. See for example point 43 of the original Rudy Salles’ report: “When it comes to preventing and combating excesses of sects, some Council of Europe member states grant significant leeway to civil society and the “traditional” churches (Catholic, Orthodox and Protestant). In this case, it is necessary to provide these stakeholders with sufficient resources for effectively performing their tasks in terms of advising and assisting the victims of such excesses and their relatives.”
For further information please contact:
All Faiths Network at
European Interreligious Forum for Religious Freedom at

[2] Georges Fenech has been convicted in 2000 as publication director after having published an anti-Semitic article in the magazine of the magistrate union over which he was presiding.
[3] Georges Fenech  2008 Report on “Justice Facing Sectarian Drifts”, p.51, Recommendation N° 12
[5] Miviludes report 2009:
[6] In her report following her official visit to France on 18-29 September 2005, Asma Jahangir, the United Nations Special Rapporteur on Freedom of Religion or Belief, noted as regards “new religious movements or communities of belief”:
  • 108. However, she is of the opinion that the policy and measures that have been adopted by the French authorities have provoked situations where the right to freedom of religion or belief of members of these groups has been unduly limited. Moreover, the public condemnation of some of these groups, as well as the stigmatization of their members, has led to certain forms of discrimination, in particular vis-à-vis their children.(…)
  • 112. The Special Rapporteur urges the Government to ensure that its mechanisms for dealing with these religious groups or communities of belief deliver a message based on tolerance, freedom of religion or belief and on the principle that no one can be judged for his actions other than through the appropriate judicial channels.
  • 113. Moreover, she recommends that the Government monitor more closely preventive actions and campaigns that are conducted throughout the country by private initiatives or Government-sponsored organizations, in particular within the school system in order to avoid children of members of these groups being negatively affected.
[7] Source : Take Care : a Sect Movie. Part 4 - 2003
[8] Source : Lectures in Ykaterinburg, 2007.
[9] Source: Conference “Origins of Islam – Untold Stories”, University of Arkhangelsk, Russia, Feb 2013.
[10] Source : Les cahiers rationalistes, # 364 December 1980
[11] “I was disgusted by the tone of the speeches there, the campaigns [FECRIS] they were making against certain religions, and how secretive they were, (…) They’re not helping people but they are actually sowing the seeds of hatred. " Bashy Quraishy, Advisory Council Chairman of European Network Against Racism (ENAR), Chair of the European Platform for Jewish Muslim Cooperation, and Secretary General for the European Muslim Initiative for Social Cohesion (EMISCO)
“FECRIS and its member associations pronounce warnings, and claim that "sects" are “dangerous". In this way, they sow fear among people who are unable to form an opinion of their own on this issue. (…) It is no coincidence that FECRIS and its member associations propagate extremely intolerant, hostile and undemocratic ways of thinking.”
Gerhard Besier - German Lutheran theologian, historian and politician -Chair in European Studies at Dresden University
“Zoran Lukovic (FECRIS rep in Serbia), in his books, articles, public appearances in the media and his overall conduct, is continuously provoking and inciting hatred, discord and intolerance of religious communities in Serbia. (…) Such atmosphere gave rise to about 300 religiously motivated incidents between 2001 and 2005 in Serbia." Youth Initiative for Human Rights
“One of the activities of FECRIS' member associations in Russia is to spread their hate message all over the former Soviet Union, in EU Orthodox countries and even in China. (…) The general atmosphere created by the hate speech of FECRIS’ Russian member association and by the media, (…) has inevitably led to violence against persons: verbal insults, physical threats or attacks, and violence against buildings: vandalism and attacks against places of worship.” Human Rights Without Frontiers
“FECRIS revisits the fights against heretics at the European level.” Prof Regis Dericquebourg - President of the European Observatory of Religions and Secularism
[15] Professor Berger was until recently the Jurisconsult of the European Court of Human Rights – a unique position responsible for case-law monitoring and preventing case-law conflicts in the Court. He is therefore in a unique position to determine the validity of the report from a European human rights and case law perspective. 
[18] See addendum 1
[20] In point 6.7 of the original resolution, it was written: “to adopt or strengthen, if necessary, legislative provisions punishing the abuse of psychological and/or physical weakness”. According to the report, this refers to the French About Picard law, which has been voted upon in 2001. This law regarding “sects” is based on so-called “psychological subjection”, which is a synonym of “mind control”. It implies that “sects” can psychologically manipulate people. This law is a remake of the Plagio law, voted in 1930 under Mussolini, creating in the penal code the criminal offence of putting someone in a “complete state of subjugation”. It has been used to eliminate opponents of Mussolini, then homosexuals but was finally was repealed by the Italian Constitutional Court in 1981, declaring it to be: “A mine floating in our judicial system that can be applied to any instance involving the psychological dependence of a human being upon another human being”. The Constitutional Court’s decision also stated: “Some typical instances of psychological dependence [...] can also reach heightened levels, over more or less extended periods, as in the case of romantic relationships, or the relationship between priest and believer, teacher and pupil, doctor and patient.”
In 2002, after the adoption of the About Picard law by the French Parliament, the Parliamentary Assembly of the Council of Europe voted a resolution (resolution 1309) inviting “the French Government to reconsider this law and to clarify the definition of the terms “offence” and “offender”. This has never been done.
Since, in 2010, the ECtHR concluded in the CASE OF JEHOVAH'S WITNESSES OF MOSCOW AND OTHERS v. RUSSIA[1] “that there is no generally accepted and scientific definition of what constitutes ‘mind control’” (point 129).

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