European rights court finds Bulgarian town’s door-to-door preaching ban breached religious freedom

The European Court of Human Rights ruled on 9 June 2026 that Bulgaria breached the religious-freedom guarantee of the European Convention when a town council banned door-to-door religious calls. In Velev and Others v. Bulgaria, application no. 56007/21, a seven-judge Chamber of the Court's Third Section held unanimously that a Shumen municipal ordinance forbidding "religious propaganda at residents' homes" violated Article 9 of the Convention, which protects freedom of thought, conscience and religion.^[1]

The measure at issue was Municipal Ordinance No. 1, Article 5(6), adopted by the Shumen municipal council on 25 February 2016. Three applicants — two individual Jehovah's Witnesses and the Witnesses' Bulgarian legal entity — challenged it, and after five years of domestic litigation the case reached Strasbourg.^[1]

The ruling is significant less for what it cost Bulgaria than for what it settled about method. The Court did not order the government to pay any damages, and none of the applicants had ever been fined or prosecuted under the ordinance. What the judges examined was the ordinance itself — a blanket, town-wide prohibition — and whether a democratic state may forbid an entire category of peaceful religious calling at people's front doors. The Court's answer was that it may not, at least not in this general form.^[1] Because this is a Chamber judgment, it is not yet final: either party may ask for the case to be sent to the Court's Grand Chamber, and the referral window runs for three months from the delivery date.^[1]

The ordinance and how it reached Strasbourg

Shumen's council introduced the ban in early 2016. A councillor elected on the list of the National Front for the Salvation of Bulgaria proposed it in January, citing resident complaints about proselytism; council committees trimmed the text to a single sentence, and the full council adopted it on 25 February 2016. Article 5(6) provided, in the Court's French-language record, that it is prohibited to conduct "religious propaganda" at residents' homes. Breach carried an administrative fine of 100 to 1,000 Bulgarian lev — roughly 50 to 500 euros — for individuals and organizations alike.^[1]

The three applicants challenged Article 5(6), and two neighbouring provisions, before the Shumen Administrative Court in July 2017. What followed was a four-decision back-and-forth. The Administrative Court first annulled all three provisions; the Supreme Administrative Court quashed that ruling and sent the case back; on remittal the lower court struck down the door-to-door ban as disproportionate but kept the other two. In its final domestic judgment of 14 May 2021, the Supreme Administrative Court reversed course on the door-to-door provision, upholding Article 5(6) as a protection of residents' private and family life and the inviolability of the home, while annulling the two sibling provisions as discriminatory toward non-traditional denominations.^[1]

That final domestic ruling — upholding the ban — is what the applicants brought to Strasbourg, lodging their application on 12 November 2021.^[1]

Applicants who were never fined

The applicants were Krasimir Dinchev Velev, a Bulgarian national resident in Sofia; Arkadiusz Krzysztof Zakrzewski, a Polish national resident in Skopje; and the Religious Institution of Jehovah's Witnesses in Bulgaria, the faith's registered Bulgarian entity. The two individuals were active members of that organization in the Shumen region at the relevant time.^[1]

A central point, and one that several early reports blurred: none of the three was ever fined or prosecuted under the ordinance. The Bulgarian Government itself told the Court that the Shumen authorities had never imposed any sanction under Article 5(6). The 100-to-1,000-lev fine was the penalty on the books, not one applied to these applicants.^[1]

Their legal standing rested instead on a chilling effect. The Court accepted that the applicants faced a dilemma — stop the door-to-door preaching that is part of their religious practice, or continue it and risk administrative punishment — and that this dilemma was enough to make them "victims" of the ban for Convention purposes, without waiting for a fine to fall. The Court reasoned by analogy to its earlier case law on laws that penalize conduct a person feels bound to perform.^[1]

What Article 9 protects, and how the Court weighed it

Article 9 protects the freedom to hold and to manifest a religion, including through worship, teaching, practice and observance. That freedom is not absolute: a state may limit the manifestation of religion where the limit is prescribed by law, pursues a legitimate aim, and is "necessary in a democratic society" — the Convention's proportionality test.^[1]

The Court worked through those limbs. It assumed without deciding the first question — whether "religious propaganda" was defined clearly enough to count as a law — flagging the term's vagueness but resolving the case on other grounds. It accepted that the ordinance pursued a legitimate aim: protecting the private life and home of residents who did not want callers. The Government had argued precisely this, contending that there was no interference at all because ordinary preaching was untouched, that "propaganda" implied manipulation, and that the ban lapsed whenever a resident consented to a visit. The residents' interest in being left alone at home was, the Court recorded, a real one.^[1]

The case turned on the final limb: proportionality. The Court characterized door-to-door preaching as central to the Witnesses' faith, drawing on its own 2023 ruling in Jehovah's Witnesses v. Finland:

The decisive problem, for the Court, was that the ban was general and absolute — it did not distinguish coercive or abusive conduct from ordinary, peaceful calling, but prohibited every form of religious propaganda at homes. In a passage the Court placed at the centre of its reasoning, it held:

On that basis the Court concluded the interference did not answer a pressing social need and was not proportionate to the legitimate aim, and therefore was not necessary in a democratic society. It found a violation of Article 9. Although the applicants had also invoked Article 10 (freedom of expression), the Court chose to examine the complaint under Article 9 alone and made no separate finding under Article 10.^[1]

No damages — only costs

The remedy is where precision matters. Each applicant had claimed 1,000 euros in non-pecuniary damages. The Court awarded none, holding that the finding of a violation was in itself sufficient just satisfaction for any non-pecuniary harm.^[1]

What the Court did award was costs and expenses: 1,000 euros to each of the three applicants — 3,000 euros in aggregate — plus any tax chargeable. Coverage describing this as "3,000 euros in compensation" is imprecise: it was 1,000 euros each toward legal costs, not damages, and the payment clock runs from the date the judgment becomes final, not from 9 June.^[1]

A Chamber judgment, not the last word

The ruling is a Chamber judgment of the Third Section, adopted unanimously by seven judges. Under Articles 43 and 44 of the Convention, such a judgment does not become final immediately. Within three months of delivery — a window that runs to roughly early September 2026 — either the applicants or the Bulgarian Government may request that the case be referred to the Court's Grand Chamber. A five-judge panel decides whether to accept any such request. The judgment becomes final if no referral is requested, if a request is refused, or, where a request is granted, once the Grand Chamber has ruled.^[1]

One caveat for readers weighing the language of the ruling: the judgment was delivered in French only. There is no official English text, so every English rendering of the Court's words — including the two passages quoted above — is an unofficial translation.^[1]

As of this writing, no public reaction from the Bulgarian Government had been located in the sources reviewed, and it is not known whether Bulgaria intends to seek Grand Chamber referral.^[1]

The wider European picture

The decision sits within a line of Strasbourg case law on religious outreach. The Court's 1993 ruling in Kokkinakis v. Greece is the seminal authority on proselytism, distinguishing protected "bearing witness" from improper or coercive attempts at conversion. For the narrower proposition that door-to-door preaching is an essential manifestation of the faith, the Velev Chamber drew on its 2023 judgment in Jehovah's Witnesses v. Finland.^[1]

Bulgaria has been before the Court on Jehovah's Witnesses' religious-freedom claims before, though on different questions. In a 2020 judgment, The Religious Denomination of Jehovah's Witnesses in Bulgaria v. Bulgaria (no. 5301/11), the Court found an Article 9 violation over obstacles to building a Kingdom Hall — a place-of-worship construction dispute, not a door-to-door case, and one the Velev judgment did not cite.^[5] The Witnesses' own communications office welcomed the Velev ruling as affirming the freedom to share their faith peacefully; as a party-affiliated account, that framing reflects the organization's position rather than a neutral assessment.^[4]

For now, Shumen's ban stands legally impugned but the case is not closed. The three-month referral window remains open, the judgment exists only in French, and whether Bulgaria will accept the Chamber's finding or ask the Grand Chamber to revisit it was, in the sources reviewed, still unknown.