CEDH · CASELAW;COMMUNICATEDCASES;ENG — 15 janvier 2026

.s800EAC49 { font-size:12pt } .s379BC09C { margin-top:36pt; margin-bottom:0pt; text-align:right } .sBB9EE52A { font-family:Arial } .s32563E28 { margin-top:0pt; margin-bottom:0pt } .s5E1364CA { margin-top:0pt; margin-bottom:12pt; text-align:center; page-break-inside:avoid; page-break-after:avoid; font-size:14pt } .s339D85E6 { margin-top:0pt; margin-bottom:14pt; text-align:center; page-break-inside:avoid; page-break-after:avoid } .s665E407E { margin-top:66pt; margin-bottom:14pt; text-align:center; page-break-inside:avoid; page-break-after:avoid } .s29100277 { font-family:Arial; font-weight:bold } .s10950C61 { margin-top:0pt; margin-bottom:0pt; text-indent:14.2pt; text-align:justify } .sA36B60A1 { font-family:Arial; font-style:italic } Published on 2 February 2026   THIRD SECTION Application no. 5825/22 Ventsislav Vasilev MINCHEV against Bulgaria lodged on 25 January 2022 communicated on 15 January 2026 SUBJECT MATTER OF THE CASE The application concerns the applicant’s conviction for defamation and insult, after he complained to bar associations about the actions of a barrister representing his ex ‑ partner in child-support and parental rights proceedings, and criticised her in private correspondence. The applicant considered that the barrister had unjustifiably initiated enforcement proceedings against him despite his regular payment of child support, and that he had been unfairly ordered to cover her legal fees arising from those proceedings. He therefore lodged complaints with two local bar associations (the one with which she was registered and the one in the city where she practised), as well as with the Supreme Bar Council. In those complaints, he alleged that the barrister had taken “unlawful and unjustified action” against him with the aim of obtaining undue legal fees, placing him in a state of “economic and financial dependence”, and coercing him into actions against his will. He further claimed that her conduct amounted to “insolent fraud or severe negligence”; that he was subjected to “constant pressure, racket and blackmail”; and that she had participated in preparing false documents (an employment contract for his ex ‑ partner) intended to pressure him into agreeing that his son live abroad with the mother. He also alleged that the barrister had presented these documents in court proceedings. A subsequent inquiry by one of the bar associations, however, concluded that the barrister had committed no disciplinary offence and had not acted contrary to professional ethics. Separately, in an email to his ex ‑ partner – which she later disclosed to the barrister – the applicant referred to the latter as, among other things, “an enraged little woman”. The barrister brought criminal proceedings for defamation and insult. In a judgment of 31 March 2021 the Shumen District Court convicted the applicant and sentenced him to a fine amounting to 5,000 Bulgarian levs   (BGN), the equivalent of 2,560 euros (EUR). It also ordered him to pay to the complainant BGN 1,000 (EUR 511) as compensation for non-pecuniary damage. The Shumen Regional Court upheld the conviction and sentence in a final judgment of 22 July 2021. The national courts acknowledged the applicant’s right to lodge complaints and to express his views. However, they found that he had exceeded the limits of permissible criticism. In particular, they held that his complaints to the Bar contained statements of fact that were untrue and defamatory, expressing an “absolutely negative judgement” of the barrister’s personality. These statements had, in their view, been made publicly and had become known to a number of people. The courts further found that both the complaints and the email to his ex ‑ partner contained insults which, although amounting to value judgments, were “unacceptable” and “degrading”. The applicant complains under Article 10 of the Convention (also relying on Article 6 § 1) that his conviction and sentence were disproportionate and unfair. QUESTION TO THE PARTIES Has there been a violation of the applicant’s right to freedom of expression, contrary to Article   10 of the Convention (see Marinova and   Others v. Bulgaria (nos. 33502/07 and 3 others, 12 July 2016))?