CEDH · CASELAW;COMMUNICATEDCASES;ENG — 12 mars 2026

.s800EAC49 { font-size:12pt } .s379BC09C { margin-top:36pt; margin-bottom:0pt; text-align:right } .sBB9EE52A { font-family:Arial } .s32563E28 { margin-top:0pt; margin-bottom:0pt } .s5E1364CA { margin-top:0pt; margin-bottom:12pt; text-align:center; page-break-inside:avoid; page-break-after:avoid; font-size:14pt } .s339D85E6 { margin-top:0pt; margin-bottom:14pt; text-align:center; page-break-inside:avoid; page-break-after:avoid } .s665E407E { margin-top:66pt; margin-bottom:14pt; text-align:center; page-break-inside:avoid; page-break-after:avoid } .s29100277 { font-family:Arial; font-weight:bold } .s10950C61 { margin-top:0pt; margin-bottom:0pt; text-indent:14.2pt; text-align:justify } .sA36B60A1 { font-family:Arial; font-style:italic } Published on 30 March 2026   FIRST SECTION Application no. 3139/25 Hrvoje ZOVKO against Croatia lodged on 21 January 2025 communicated on 12 March 2026 SUBJECT MATTER OF THE CASE The application concerns civil proceedings for wrongful dismissal instituted by the applicant against his employer. The applicant is the president of the Croatian Journalists’ Association. Since   2001 he also worked at the Croatian Radio-Television (a public broadcasting organisation), most recently as an executive programme editor. In March 2018 he announced his resignation from his editor duties, owing to alleged censorship by the hierarchy. A verbal incident then occurred at a meeting held between him and his direct superior, who is also an editor. During the incident the applicant yelled, swore and slammed the door. He was deemed to have displayed on that occasion insults, threats and physical violence against his superior and four other colleagues and was summarily dismissed. In 2019 the Zagreb Municipal Labour Court found that the applicant’s dismissal was wrongful. It considered that the language used had been a demonstration of frustration with the alleged denial of editorial autonomy and had not been personally directed against his superior, who had also uttered swears. It found that the applicant’s behaviour on the occasion had not been violent or threatening against five colleagues, or caused them fear, as alleged in the dismissal, as he had only exchanged with one of them. In 2020 the Rijeka County Court upheld that judgment. It noted that the applicant’s behaviour had been entirely inappropriate, but that it had not warranted a summary dismissal. During the many years of working at the television the applicant had never displayed inappropriate behaviour, and the verbal incident had occurred with a person with whom he had worked for twenty years. It further noted that verbal conflicts and loud expressions of frustration were not unusual in broadcast editing, which is a highly stressful environment. In 2024 the Supreme Court granted an appeal on points of law by the defendant and overturned the lower courts’ judgments. Referring to two of its previous judgments, that court held that, by verbally attacking his employer, the applicant had committed a particularly severe breach of working obligations, and that the continuation of the working relationship was no longer possible (cumulative statutory criteria for summary dismissal). The applicant lodged a constitutional complaint, complaining that the Supreme Court’s decision was arbitrary and lacked reasons with respect to the finding that the incident had involved an attack of an employee against an employer. He argued that he had had a verbal conflict with a person who is an editor like him and could not be deemed his employer. He thus challenged the application of Supreme Court’s case-law regarding employee-employer attack, instead of case-law regarding verbal conflict between employees. He also challenged the Supreme Court’s conclusion about continuation of the working relationship not being possible, in particular since, between the incident and the Supreme Court’s decision, he had continued working at the editor’s post. On 12 September 2024 the Constitutional Court dismissed the applicant’s constitutional complaint as unfounded, and on 23 September 2024 notified him of its decision. Before the Court the applicant complains, under Article   6 §   1 of the Convention, that the Supreme Court’s decision was arbitrary and lacked reasons regarding the key aspects of the case and that the Constitutional Court failed to address his arguments. QUESTIONS TO THE PARTIES Did the applicant have a fair hearing in the determination of his civil rights and obligations, in accordance with Article 6 § 1 of the Convention? In particular, were the decisions of the Supreme Court and the Constitutional Court sufficiently reasoned and not arbitrary (see Zahariev v.   North   Macedonia , no. 26760/22, §§ 42-43 and 49-50, 5   November   2024; Paun Jovanović v.   Serbia , no. 41394/15, §§ 100-01, 7 February 2023; and Anđelković v.   Serbia , no. 1401/08, § 24, 9 April 2013)?