Russia¶
The cases here show the sequence completed and administered as routine. A label for foreign ties becomes the ground for liquidation, a court defines the organisation it then bans, and the memory of earlier purges is itself treated as the offence. Each instrument rests on the one before: the register supplies the violation, the violation supplies the dissolution, and the designation reaches anyone who can be connected. International judgments against the label have not changed its use, so the courts that might check the sequence are the ones carrying it out.
The clerk’s briefs¶
From the clerks, for the Patrician’s eyes
Read these, as the parts catalogue. Anyone who has worked with any part of the movement can now be charged as a member, the work inside the country has stopped, and the archives of past abuses lose their keepers. States drafting foreign-agent laws elsewhere can point to a working model, and its vocabulary turns up in their drafts. The instruments would lose their force only with a government willing to repeal them, and nothing on file suggests one.
April 2026: The movement that does not exist¶
On 9 April 2026 the Supreme Court designated the “International Memorial public movement” an extremist organisation. Memorial said “the organization named in the court’s ruling does not exist”; it comprises dozens of distinct groups. The Memorial Human Rights Center suspended all work inside Russia the same day. The clerks note that a court has banned a movement defined by the court, which makes anyone connected to any part of it a possible member.
June 2022: Strasbourg on the label¶
On 14 June 2022 the European Court of Human Rights ruled in Ecodefence and others v. Russia, brought by 73 organisations, that the “foreign agent” label was “unjustified and prejudicial and also liable to have a strong deterrent and stigmatising effect”, and unanimously found a violation of freedom of association. The clerks note that a court named the first step of the historical record in a judgment, and the state it was addressed to kept the label.
December 2021: Memorial liquidated¶
On 28 December 2021 the Supreme Court ordered the liquidation of International Memorial, whose main aim was to uncover and archive evidence of Soviet-era human rights abuses, mainly for failing to comply with the foreign agents law, including the requirement to label all its materials. The next day the Moscow City Court dissolved the Memorial Human Rights Center, which kept the list of political prisoners. The clerks note that the society that kept the record of the last purge was liquidated under the register of the present one.