Article 9 — Freedom of thought, conscience and religion
How Article 9 ECHR may apply to sincerely held ethical convictions, including veganism.
Established law and case law
What the Convention protects
Article 9(1) protects the inner freedom of thought, conscience and religion absolutely, and the outward manifestation of a belief in worship, teaching, practice and observance subject to the limitations in Article 9(2). A non-religious conviction is protected where it meets the Campbell and Cosans test: cogency, seriousness, cohesion and importance, and worthy of respect in a democratic society.
Diet as manifestation
In Jakóbski v. Poland the Court accepted that adherence to a meat-free diet motivated by belief was a manifestation of that belief, and found a violation where the authorities refused accommodation that would not have caused disproportionate difficulty. Vartic v. Romania (No. 2) confirmed that reasoning.
FFVR analysis — argument, not settled law
FFVR's argument
FFVR argues that ethical veganism satisfies the Campbell test and that the Jakóbski reasoning is not confined to religious motivation, since Article 9 treats conscience and religion on the same footing. The Court has not yet ruled directly on ethical veganism and institutional catering, so this remains argument rather than established law.
Sources
European Convention on Human Rights
Council of Europe · 1950-11-04 · ETS No. 005
Primary sourceJakóbski v. Poland
European Court of Human Rights · 2010-12-07 · App no 18429/06
Primary sourceVartic v. Romania (No. 2)
European Court of Human Rights · 2013-12-17 · App no 14150/08
Primary sourceCampbell and Cosans v. the United Kingdom
European Court of Human Rights · 1982-02-25 · App nos 7511/76 and 7743/76
The information provided by FFVR is intended for general informational and educational purposes. It is not individual legal advice. The legal analysis presented on this website includes both established law and FFVR's interpretation of relevant legal principles. Where FFVR advocates for a particular legal development, this should not be understood as a statement that such a right already exists under Swedish law.