37 sector of the population.151 In a democratic society, the media must provide extensive information on matters of public interest, which affect social rights […].”152 Nevertheless, the Court is aware that the extent of acceptable criticism when directed against a private individual is narrower than that directed against politicians or public officials in the exercise of their functions. 153 118. With regard to the statements published in the interview, the Court considers that, in general, they reveal that the purpose sought by Mr. Lagos del Campo was to denounce alleged irregularities; in other words, to provide information on a situation that, in his opinion, violated the interests he represented,154 accompanied perhaps by critical comments and opinions. Conversely, the content of those statements in this context does not reveal that they had an evident offensive, defamatory, degrading or malicious intent against anyone in particular or that they were aimed at harming the company’s product (supra para. 112). Although the publication contained bombastic phrases concerning the situation denounced, their content did not exceed the threshold of special protection for the nature of the complaints made in the said context.155 1.2.2. Legality and purpose 119. According to Article 13(2), to evaluate whether a restriction of a right established in the American Convention is permitted in light of this treaty it is necessary to analyze whether the restrictive measure complies with the requirement of legality. This means that the general circumstances and conditions that authorize restrictions of a human right must be clearly established by law, in both the formal and the substantial sense. 156 120. Regarding restrictions of a criminal nature, the Court has established that it is necessary to abide strictly by the requirements that are characteristic of the definition of the crime in order to comply with the principle of legality.157 However, the Court notes that the law applied to justify Mr. Lagos del Campo’s dismissal was not of a criminal nature, but rather a labor law. Therefore, it considers that compliance with the requirement of legality does not require the same evaluation as that made in cases that involve the violation of rights protected by criminal law because, as the Court has indicated when evaluating compliance with the requirement of legality in cases that do not involve criminal matters, “the degree of precision required of domestic legislation depends Cf. Case of “The Last Temptation of Christ” v. Chile, supra, para. 69, and Case of Kimel v. Argentina, supra, para. 88; ECHR, Case of Palomo Sánchez and Others v. Spain [GS], supra, para. 53 to 62. 151 152 Case of Kimel v. Argentina, supra, para. 88. Case of Palomo Sánchez and Others v. Spain [GS], supra, para. 42. and ECHR. Case of Nikula v. Finland, No. 31611/96. Judgment of March 21, 2002. para. 48 153 Mutatis mutandis: ILO Convention 98: Right to Organize and Collective Bargaining, 1949 (Entry into force: July 18, 1951). Adopted: Geneva, Thirty-second meeting of the ILO General Conference (July 1, 1949). 2.1 Workers' and employers' organisations shall enjoy adequate protection against any acts of interference by each other or each other's agents or members in their establishment, functioning or administration. 2.2 In particular, acts which are designed to promote the establishment of workers' organisations under the domination of employers or employers' organisations, or to support workers' organisations by financial or other means, with the object of placing such organisations under the control of employers or employers' organisations, shall be deemed to constitute acts of interference within the meaning of this Article. 154 ECHR. Case of Fuentes Bobo v. Spain. No. 39293/98. Judgment of February 29, 2009. para. 40. The Court, while acknowledging that the phrases used were offensive, concluded that they occurred in a context of a “prolonged public debate concerning matters of general interest relating to the management of public television.” Cf. ILO, Recommendation on Workers’ Representatives, 1971 (No. 143), Recommendation on protection and facilities that should be afforded to workers’ representatives. Fifty-sixth Session of the ILO General Conference; date adopted June 23, 1971. See also. Mutatis mutandis: ILO, Freedom of Association and Collective Bargaining” para. 212, p. 96. 155 Cf. The Word “Laws” in Article 30 of the American Convention on Human Rights. OC-6/86, supra, paras. 35 and 37; Case of Mémoli v. Argentina, supra, para. 130, and Case of Granier et al. v. Venezuela, supra, para. 119. 156 Cf. Case of Castillo Petruzzi et al. v. Peru. Merits, reparations and costs. Judgment of May 30, 1999. Series C No. 52. para. 121; Case of Kimel v. Argentina, supra, para. 63, and Case of Memolí v. Argentina, supra, para. 154 157

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