29/09/2023, 12:35 SANCHEZ v. FRANCE - 45581/15 (Judgment : No Article 10 - Freedom of expression-{general} : Grand Chamber) [2023] ECHR 418 (1… 80. In the light of the reasoning of the domestic courts, the Court must, in accordance with its settled case-law, examine whether their finding of liability on the part of the applicant was based on relevant and sufficient grounds in the particular circumstances of the case (see, in relation to a major Internet news portal, Delfi AS, cited above, § 142). In doing so, and in assessing the proportionality of the impugned penalty, it will consider the context of the comments, the steps taken by the applicant to remove the comments once posted, the possibility of holding the authors liable instead of the applicant and, lastly, the consequences of the domestic proceedings for the applicant (see, inter alia, Delfi AS, cited above, §§ 142-43, and Jezior v. Poland [Committee], no. 31955/11, § 53, 4 June 2020).” 168. The Grand Chamber sees no reason to depart from that approach and will also follow it for the purposes of its examination of the present case. (i) Context of the comments at issue (α) Nature of impugned comments 169. While referring back to its survey of the case-law on this question (see paragraphs 154-157 above), the Court would first note that there is no universal definition of “hate speech” (see, concerning the work of the Committee of Ministers of the Council of Europe, paragraphs 60 et seq. above). 170. The Court would then point out that the present case concerns the posting, by two different authors, of a number of disputed comments. The first comment was posted by S.B., who referred to “Leilla” (sic) and “Franck” (see paragraph 15 above). The Court notes that Leila T., F.P.’s partner, considered that it had targeted her personally. The other three comments were posted by a single author, L.R. 171. The Court finds it necessary to examine the content of the remarks in question, particularly in the light of the reasoning given by the domestic courts. 172. In this connection it would first observe that the Criminal Court, in its judgment of 28 February 2013, began by noting that the remarks had “perfectly” defined a specific group of persons, namely Muslims, using phrases such as “the UMP and the PS are allies of the muslims” or “drug trafficking run by the muslims”, but also in conjunction with words such as “kebab”, “mosque”, “sharia”, “shisha bars” and “hallal economic devellopment” (see paragraphs 15, 16 and 26 above). The Court shares this view, adding that the words “veiled women”, from a comment by L.R., also clearly denoted Muslims (see paragraph 16 above). https://www.bailii.org/eu/cases/ECHR/2023/418.html 67/100