@downey
4. hi this brief, we conclude that
0 Article 20.3.3 of the Russian Federation Code of Administrative Offenses (“Alticle
20.3.3”) 7 which prohibits, in summary, any form of criticism of the use of armed forces1
and execution by state bodies of their powers outside of the territory of the Russian
Federation2 and imposes sanctions when violated3 7 restricts the rights to freedom of
expression of j ournalists, activists, and the general public in Russia protected by Article
19(2) of the International Covenant on Civil and Political Rights (ICCPR); and
0 Article 20.3.3. does not pass the stringent test of legality, legitimacy, and necessity and
proportionality under Article 19(3) of the ICCPR.
Therefore, we respectfully urge the Court to declare that Article 20.3.3 is unconstitutional and
illegal, in accordance with the international legal rule that people may not be penalized for or
restricted from criticizing public institutions.