Life and Education > Work, Free Time, Holidays, etc.

Parental rights to make decisions regarding work, free time, holidays, etc.

Taganrog LRO and Others v. Russia

Nos. 32401/10 and 19 others, 7 June 2022

“172. … It is a common feature of many religions that they determine doctrinal standards of behaviour by which their followers must abide in their private lives, including matters such as attendance at church services, performance of rituals, wearing specific clothes or observing dietary restrictions. Jehovah’s Witnesses’ regulations on engaging in door-to-door preaching and attendance at religious meetings are no different from similar limitations that other religions impose on their followers’ private lives. By obeying these precepts in their daily lives, believers manifest their desire to comply strictly with the religious doctrine they profess and their freedom to do so is guaranteed by Article 9 of the [European Convention on Human Rights] …

173. The Court reiterates that Article 2 of Protocol No. 1 [to the European Convention on Human Rights] requires the State to respect the rights of parents to ensure education and teaching in conformity with their own religious convictions and that Article 5 of Protocol No. 7 establishes that spouses enjoy equality of rights in their relations with their children. … Both parents, even in a situation where they adhere to differing doctrines or beliefs, have the right to raise their children in accordance with their religious or non-religious convictions …”

“175. As long as there is no evidence of abuse, violence or unlawful coercion, decisions about whether to give a child a religious or non-religious education, whether to involve him or her in sports, science, arts or music, whether to provide unstructured free time or a strict daily routine, and whether to keep company with like-minded people, are to be made exclusively by the child’s parents or, as the case may be, the custodial parent. Such decisions fall within the sphere of the private and family life which is protected from unjustified State interference. It follows that what was taken by the Russian courts to constitute impermissible involvement of minors was in fact a manifestation of the parents’ beliefs in their private lives in the sense protected by Article 9 …” (Original in English.)

Jehovah’s Witnesses of Moscow and Others v. Russia

No. 302/02, 10 June 2010

“117. The Court reiterates that “private life” is a broad term encompassing the sphere of personal autonomy within which everyone can freely pursue the development and fulfilment of his or her personality and to establish and develop relationships with other persons and the outside world. … In the light of these principles, the decisions of Jehovah’s Witnesses whether to take full-time or part-time, paid or unpaid employment, whether and how to celebrate events significant to them, including religious and personal events such as wedding anniversaries, births, housewarmings, university admissions, were matters that fell within the sphere of “private life” of community members.

118. The Court emphasises that it is a common feature of many religions that they determine doctrinal standards of behaviour by which their followers must abide in their private lives. Religious precepts that govern the conduct of adherents in private life include, for instance, regular attendance at church services, performance of certain rituals such as communion or confession, observance of religious holidays or abstention from work on specific days of the week … wearing specific clothes … dietary restrictions … and many others Jehovah’s Witnesses’ regulations on allowing sufficient time for religious activities and abstaining from celebrating non-Witnesses or secular events were in that sense not fundamentally different from similar limitations that other religions impose on their followers’ private lives. By obeying these precepts their daily lives, believers manifested their desire to comply strictly with the religious beliefs they professed and their liberty to do so was guaranteed by Article 9 of the [European Convention on Human Rights] in the form of the freedom to manifest religion, alone and in private.”

152. Finally, ‘participation in celebrations during State holidays’ is not a civil duty as defined by law. In fact, there is no law compelling celebration of any holidays, whether they are secular or religious, and such compulsory participation in celebrations, had it been elevated to the rank of a legal obligation, could arguably have raised an issue under Articles 9 and 10 of the Convention.” (Original in English.)