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The ECtHR's ruling in ES v Austria raises questions about the Court's methodology in blasphemy cases. The ECtHR interprets Article 9 of the Convention as including a right to respect for religious feelings and presumes that 'justified indignation' may disrupt 'religious peace'. Therefore, expression counting as 'gratuitously offensive' to religious feelings is not granted protection under Article 10. es v Austria reveals certain problems that arise when criticism of religion is driven by hatreddoi:10.1163/26663236-bja10008 fatcat:ktv5f5mu3fa35foyxt4lxt5rsu