Savez crkava “Riječ života” and Others v. Croatia, No. 7798/08, ECtHR (First Section), 9 December 2010

Lack of official recognition by Croatian authorities of reformist churches.

Art. 14 ECHR
Art. 1 Prot. 12 ECHR

1. The Convention does not impose any obligation on Member States to have the effects of religious marriages recognised as equal to those of civil marriages, or to provide religious instruction in public schools and kindergartens. Croatia allows certain religious communities to provide religious instruction in public schools and recognised religious marriages celebrated by these communities.

2. States enjoy a discretionary power in deciding whether or not to enter into an agreement with a religious community. However, here it is considered that the non-recognition of the Reformed Churches constitutes discrimination by a public authority in the exercise of a discretionary power, as similar situations are treated differently.
(The Reformed Churches did not obtain their official recognition by the Croatian authorities due to the lack of two cumulative criteria, which were not applied to other religious associations).