12 NISKASAARI AND OTAVAMEDIA OY v. FINLAND JUDGMENT him of disseminating false information and fabricating figures (see paragraph 18 above). He was convicted by the Appeal Court because it had not been found to be proved in the proceedings before that court that the complainant had disseminated wrong or misleading information in the television documentaries in question, with the consequence that the first applicant had not had strong reasons or probable cause to hold his own accusations to be true. Nor had the first applicant had the right to call the complainant a liar. On these grounds the Appeal Court found the first applicant guilty of defamation. 52. In order to assess whether the “necessity” of the restriction of the exercise of the freedom of expression has been established convincingly, the Court must, among other things, examine whether the balancing exercise between the freedom of expression and the right to respect for private life, including the right to reputation, has been undertaken by the national authorities in conformity with the criteria laid down in the Court’s case-law. 53. The Court considers that the general subject-matter which was at the heart of the article and the internet discussions in question, namely the limits of critical and investigative journalism, was clearly a matter of legitimate public interest. The journalism criticised by the applicant related in particular to the topics of the television documentaries which concerned mould-infested houses and the protection of forests. At first instance, the District Court had found that, while the documentaries made by the complainant had provoked public discussion, they had also, on account of the manner in which they were presented, provoked harsh criticism. From the point of view of the general public’s right to receive information about matters of public interest, and thus from the standpoint of the press, there were therefore justified grounds for discussing the limits of critical and investigative journalism in the public domain (see paragraph 16 above). 54. Both parties to these discussions were professional journalists who were relatively well-known to the general public. The discussions were published on two internet discussion sites, namely on the “Ylevi” site maintained by the Green League (Vihreä liitto, Gröna förbundet) and the “Journalism” site maintained by Tampere University. The impugned article was published in the weekly magazine Seura, which is one of the biggest nationwide family magazines in Finland. Moreover, it is also noteworthy that Seura magazine provided the reporters who had made the documentaries in question, including the complainant, with an opportunity to reply to the first applicant’s criticism. In response to this reply, the magazine subsequently published a page-long counter-reply by the first applicant (see paragraph 11 above). 55. There is no suggestion that details of the article or the internet discussions were obtained by subterfuge or other illicit means (compare Von Hannover v. Germany, no. 59320/00, § 68, ECHR 2004-VI). On the contrary, the details were based on the two television documentaries