OOO FLAVUS AND OTHERS v. RUSSIA JUDGMENT been made without advance notification to the parties whose rights and interests were likely to be affected. The law did not require the authorities to carry out an impact assessment of the blocking measures prior to their implementation or justify the urgency of their immediate enforcement without giving the interested parties the opportunity to remove the illegal content or apply for a judicial review. The blocking measures had not been sanctioned by a court or other independent adjudicatory body providing a forum in which the interested parties could have been heard. 41. The Court further notes that the Information Act does not require the authorities to justify the necessity and proportionality of the interference with the freedom of expression online or consider the question whether the same result could be achieved by less intrusive means. Nor does it require them to ascertain that the blocking measure strictly targets the illegal content and has no arbitrary or excessive effects, including those resulting from the blocking of access to the entire website. 42. As regards the transparency requirement, the Information Act makes no provision for communicating the blocking request under section 15.3 to the owners of the targeted websites. In the present case, the applicants had been unaware of the grounds for the blocking request until after access to their websites had been blocked and they had applied for a judicial review (see paragraph 7 above). 43. Lastly, as regards the proceedings which the applicants instituted to challenge the blocking measures, the Court has previously found that the breadth of the executive’s discretion under section 15.3 is such that it is likely to be difficult, if not impossible, to challenge the blocking measure on judicial review (see Kablis, cited above, § 96). There is no indication that the judges considering their complaints sought to weigh up the various interests at stake, in particular by assessing the need to block access to the entire websites. In the Court’s view, this shortcoming was a consequence of the domestic courts’ failure to apply the Plenary Supreme Court’s Ruling no. 21 of 27 June 2013, which required them to have regard to the criteria established in the Convention in its interpretation by the Court (see Lashmankin and Others v. Russia, nos. 57818/09 and 14 others, § 217, 7 February 2017). In reaching their decision, the courts confined their scrutiny to establishing that the Prosecutor General and Roskomnadzor had exercised the discretion which the legislation had afforded them (see paragraphs 9 and 10 above). However, in the Court’s view, a Conventioncompliant review should have taken into consideration, among other elements, the fact that such a measure, by rendering large quantities of information inaccessible, substantially restricted the rights of Internet users and had a significant collateral effect (see Ahmet Yıldırım, cited above, § 66). 15