SPECIAL COLLECTION OF THE CASE LAW ON FREEDOM OF EXPRESSION The need to adopt protection against SLAPPs has been recognised in the reports of the special mandates – in particular, the special rapporteurs on freedom of peaceful assembly and extrajudicial, summary, or arbitrary execution;23 the special rapporteur on freedom of expression, the OSCE representative on freedom of media, and the UN Working Group on Business and Human Rights.24 On a regional level, the European Parliament has called for specific anti-SLAPP legislation since 2018. In November 2021, the Parliament adopted an own-initiative report on SLAPPs that called on the European Commission to present a comprehensive package of measures against SLAPPs, including legislation.25 Since 2020, the European Commission has been working on the EU directive on the topic, which is currently in the proposal stage.26 In November 2021, the Council of Europe’s Committee of Ministers, made up of the foreign ministers of each of the member States, established a committee of experts on SLAPPs and tasked it with drafting a Recommendation on SLAPPs by the end of 2023.27 No similar initiatives have been undertaken by other regional human rights bodies, such as those in the Inter-American system or in Africa. Regional courts have also examined SLAPP cases, as explored later in this study. For example, the European Court did it for the first time in Steel and Morris v United Kingdom (2005).28 Although the Court did not explicitly mention the concept of SLAPPs as such, it looked at the unfairness of the proceeding resulting from the denial of legal aid to applicants to protect their right to freedom of expression in a defamation case brought by a global corporation.29 The next section examines the subsequent SLAPP cases on regional and national levels. 23 UN HRC, Joint report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association and the Special Rapporteur on extrajudicial, summary or arbitrary execution on the proper management of assemblies, UN Doc.A/HRC/31/66, 4 February 2016, para 84. 24 UN Working Group on Business and Human Rights, Guidance on National Actions Plans on Business and Human Rights, 2016, p. 31. 25 European Parliament resolution of 11 November 2021 on strengthening democracy and media freedom and pluralism in the EU: the undue use of actions under civil and criminal law to silence journalists, NGOs and civil society (2021/2036(INI). 26 See the Proposal for a directive of the European Parliament and of the Council on protecting persons who engage in public participation from manifestly unfounded or abusive court proceedings (“Strategic lawsuits against public participation”), April 2022. 27 Committee of Experts on SLAPPs, set up by the Committee of Ministers under Article 17 of the Statute of the Council of Europe and in accordance with Resolution CM/Res(2021)3 on intergovernmental committees and subordinate bodies, their terms of reference and working methods. 28 European Court, Steel and Morris v. United Kingdom, App. No. 68416/01, (2005). 29 Ibid., paras 61, 63 and 67. 10