110. This does not mean that speech protected by its public interest, such as statements referring to the conduct of public officials in the exercise of their duties, or the honor of public officials or public figures, should not be legally protected. Journalistic conduct could potentially result in liability in another legal sphere, such as in civil law, or could require rectification or public apologies, for example, in cases of possible abuses or excesses of bad faith. 111. The Court has stated that, in a democratic society, individuals who have an impact on matters of public interest are more exposed to public scrutiny and criticism. A different threshold of protection is applied because their activities go beyond the domain of the private sphere and belong to the realm of public debate. Therefore, they have voluntarily laid themselves open to a more intense public scrutiny.141 This in no way means that the honor of those who take part in matters of public interest should not be legally protected, but that it should be protected in accordance with the principles of democratic pluralism.142 112. On this point, the European Court of Human Rights has repeatedly held that public officials must be willing to accept a greater degree of criticism than private individuals. It has also established that, “the limits of acceptable criticism are accordingly wider with regard to a politician acting in his public capacity than in relation to a private individual. The former inevitably and knowingly lays himself open to close scrutiny of his every word and deed by both journalists and the public at large, and he must display a greater degree of tolerance, especially when he himself makes public statements that are susceptible to criticism.”143 According to the European Court, “the limits of permissible criticism are wider with regard to the Government than in relation to a private citizen, or even a politician. In a democratic system, the actions or omissions of the Government must be subject to the close scrutiny not only of the legislative and judicial authorities but also of the press and public opinion. Furthermore, the dominant position which the Government occupies makes it necessary for it to display restraint in resorting to criminal proceedings, particularly where other means are available for replying to unjustified attacks and criticisms by its adversaries or the media.”144 113. For its part, the African Court of Human and People’s Rights has stated that “freedom of expression in a democratic society must be the subject of a lesser degree of interference when it occurs in the context of public debate relating to public figures.” It has also reiterated that “people who assume highly visible public roles must necessarily face a higher degree of criticism than private citizens; otherwise, public debate may be stifled altogether.”145 114. The Court recalls that it considers as topics of public interest those opinions and statements on matters regarding which society has a legitimate interest to be informed, in order to be aware of anything that affects the performance of the State or impacts rights or general interests or anything that has significant consequences.146 This includes statements on environmental matters. In this regard, the Court believes that the opinions, expressions, ideas and information related to the protection or management of the environment, as well as those on the environmental risks and impact of activities or projects, should be considered 141 Cf. Case of Herrera Ulloa v. Costa Rica, supra, para. 129, and Case of Moya Chacón et al. v. Costa Rica, supra, para. 75. 142 Cf. Case of Herrera Ulloa v. Costa Rica, supra, para. 128, and Case of Moya Chacón et al. v. Costa Rica, supra, para. 75. 143 Cf. ECHR, Case of Oberschlick v. Austria, No. 11662/85. Judgment of May 23, 1991, para. 59. 144 Cf. ECHR, Case of Castells v. Spain, no. 11798/ 85. Judgment of April 23, 1992, para. 46; Case of Fatullayev v. Azerbaijan, No. 40984/07. Judgment of April 22, 2010, para. 116, and Otegi Mondragon v. Spain, No. 2034/07. Judgment of March 15, 2011, para. 58. 145 Cf. ACHPR, Case of Lohé Issa Konaté v. Burkina Faso. Application 004/2013. December 5, 2014; para. 155. 146 Cf. Case of Tristán Donoso v. Panama, supra, para. 121, and Case of Moya Chacón et al. v. Costa Rica, supra, para. 74. 35