GREEN ALLIANCE C. BULGARIE: LA SURVEILLANCE ÉTATIQUE DE LA SOCIÉTÉ CIVILE FACE AUX EXIGENCES CONVENTIONNELLES
GREEN ALLIANCE C. BULGARIA: STATE SURVEILLANCE OF CIVIL SOCIETY IN THE FACE OF CONVENTIONAL REQUIREMENTS

Summary/Abstract: The judgment Green Alliance v. Bulgaria, delivered on 17 February 2026 by the European Court of Human Rights, marks a significant milestone in the development of the protection afforded by Article 8 of the Convention. For the first time, the Court applies the criteria developed in Roman Zakharov v. Russia to a system of human surveillance – the infiltration of “agents on cover” into private organisations and liberal professions – and finds that the mere existence of the Bulgarian legislative framework suffices to constitute an unjustified interference with the right to respect for private life and the home. Beyond its immediate legal significance, the judgment forms part of a line of case law that reveals deep structural failures of the rule of law in Bulgaria. The article examines in turn the contribution of the judgment to the case law on Article 8 of the ECHR, its systemic dimension, and the practical limits of its impact in the Bulgarian context.

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