SPECIAL COLLECTION OF THE CASE LAW ON FREEDOM OF EXPRESSION 2. Case law After presenting our general analysis of the international and regional standards applicable to internet shutdowns and similar restrictions to the access to the internet by state authorities, this paper will now focus on how the most important and accessible case law decisions, both at regional and national levels, have so far considered these matters. 2.1 Case law from regional human rights courts European Court of Human Rights The European Court of Human Rights (ECtHR) has not issued any ruling regarding internet shutdowns in member States of the Council of Europe. However, the ECtHR has adopted several decisions interpreting the scope of protection of the right to freedom of expression in the digital world. Some of these decisions refer to measures adopted by States preventing access to certain content, services, or online applications, including the wholesale blocking of opposition online media outlets (OOO Flavus and others v. Russia), or the blocking of a website for hosting what the domestic courts considered to be prohibited content (Engels v. Russia, Vladimir Kharitonov v. Russia and Bulgakov v. Russia). It also needs to be noted, as stressed by the Court in the decision on the case of Ahmed Yildirim v. Turkey, that restrictions to online content, contemplated by national legislation of Council of Europe States, include “a wide variety of approaches and legislative measures, ranging from the suspension of individual rights of internet access or the removal of the illegal content, to the blocking of access to the specific website in question.” The Court adds that in most European countries “the protection of the rights of minors and efforts to combat the sexual exploitation of minors constitute a basis for appropriate measures restricting access to the websites concerned (this is the case in France, Germany, Switzerland and the United Kingdom). When it comes to ordinary crime, the measures restricting access are different and less severe in six countries (Austria, Estonia, Finland, Italy, Lithuania and the Netherlands).” In countries such as France or Spain, legislation was passed to permit the imposition of certain internet access restrictions to protect the holders of copyright and related rights. However, it is also important to note here the decision of the Constitutional Council of France from 2009 establishing the principle that the legislature may not confer powers to restrict or prevent internet access on an administrative authority. For the purposes of this paper, the decision in the Ahmed Yildirim v. Turkey case probably constitutes the most important contribution by the ECtHR in this field. The applicant owned and ran a website on which he published his academic work and his views on various topics. The website was created using the Google Sites website creation and hosting service. Based on Turkish Law no. 5651 on regulating Internet publications and combating internet offences, and following the order of the Denizli Criminal Court of First Instance, the Telecommunications and Information Technology Directorate (TIB), an administrative regulatory body, blocked all access to Google Sites and the applicant was thus unable to access his own website. 25