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  1. The Larissis and Others against Greece
  2. A polemic argument
  3. Suggested solutions
  4. Peggy Hermann

The Larissis and Others against Greece in 1998 shows an evolution of the case law on proselytism. Facts: three officers of the Greek army, a member of the Pentecostal Church and are convicted by a court of proselytizing the army.
The Court takes the term "improper proselytism". Thus in paragraph 45 it is stated that this qualification is justified when the pressures are abusive. On the other hand, benefits or property that are offered to the caller depends on its adherence to religious grouping. The Court operates control measures taken by the national authorities, particularly regarding proportionality. Thus, in this case, unlike the case of Kokkinakis against Greece, the degree of freedom of the interlocutor is considered.

The Court distinguished "proselytism exercised with the soldiers and that charged to civilians." In the first case, Greece has not violated Article 9.1 of the Convention, the latter having abused their hierarchical position. This does not even measures which concerned the applicants who had sent civilians since no undue pressure or coercion are observed ( 59) and any special protection of the speakers was required.

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