GLUKHIN v. RUSSIA JUDGMENT risks posed by the solo demonstration or verified whether it had been necessary to arrest and convict him. 50. The Government submitted that the domestic law required prior notification of public events. The applicant had been lawfully convicted for failure to respect that requirement. His escorting to the police station and his arrest had also been lawful. 51. The Court reiterates that the protection of Article 10 is not limited to the spoken or written word, for ideas and opinions are also capable of being communicated by non-verbal means of expression or through a person’s conduct (see Karuyev v. Russia, no. 4161/13, § 18, 18 January 2022). Given the nature and the context of the applicant’s conduct, the Court considers that through his actions he sought to express his opinion on a matter of public interest, in respect of which there is little scope for restrictions under Article 10 § 2. 52. The applicant’s escorting to the police station, administrative arrest and conviction for an administrative offence constituted an interference with his right to freedom of expression (see Novikova and Others, cited above § 106). 53. The relevant general principles were summarised in Novikova and Others (cited above, §§ 190-201) and Kudrevičius and Others v. Lithuania ([GC], no. 37553/05, §§ 108-10, 150-51 and 155, ECHR 2015). 54. As regards the “prescribed by law” criterion, the provision on “quickly (de)assembled objects” contained no criteria allowing a person to foresee what kind of objects could be covered by that provision. Having regard to the nature of the applicant’s solo demonstration, and in the absence of either further clarifications concerning the scope and manner of application of the relevant provisions by higher Russian courts or any detailed analysis by the domestic courts in the applicant’s specific case, the Court finds that there is reason to doubt that the manner of application of the impugned legal provisions was sufficiently foreseeable to meet the quality requirement in the case at hand (see Navalnyy v. Russia [GC], nos. 29580/12 and 4 others, § 118, 15 November 2018). 55. However, even assuming that the interference was in accordance with the law and pursued the legitimate aims of “the prevention of disorder” and “the protection of the rights of others”, it was not “necessary in a democratic society” for the following reason. 56. The applicant’s solo demonstration was carried out in an indisputably peaceful and non-disruptive manner. The offence of which he was convicted consisted merely of a failure to notify the authorities of his solo demonstration and included no further incriminating element concerning any reprehensible act, such as the obstruction of traffic, damage to property or acts of violence (contrast Kudrevičius and Others, cited above, §§ 164-75). It was not established that the applicant’s actions caused any major disruption to ordinary life and other activities to a degree exceeding that which was normal 19

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