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In the Name of the Father

Despite wide-spread criticism that it prioritises the rights of parents — in fact, fathers — over those of children, the Greek government recently enacted a major reform of family law, radically changing provisions regarding the custody of children after a divorce. But was this a progressive measure, or a hijack of the legislative process by a minority of “men’s rights” advocates who used their political connections to push the new law through Parliament?

Athens

© The Manifold

Over a year ago, an unprecedented advertising campaign appeared in the streets of Athens: part of it was authorless and guerrilla-like, graffiti or banners hanging on road bridges and overpasses with slogans such as “joint custody” and “dads are not visitors, they are parents”; and part of it had the hallmarks of high-powered lobbying, with posters calling for “equal time with both parents” and “alternating homes” covering advertising spaces in bus stops all over the city.

The bus stop posters, sponsored by Politis Group, a major street advertising company, bore the logo of an organisation named “Active Dads for Children’s Rights”. Other organisations, such as the “Joint Custody Association”, and the Association GON.IS., also became more vocal in the press and in social media in advocating for the overhaul of child custody laws. 

A few months previously, the minister of Justice, Kostas Tsiaras, had appointed a legislative committee tasked with drafting a bill that would reform Greek family law. Konstantinos Bogdanos, a member of Parliament for New Democracy, whose candidacy and parliamentary tenure have been as controversial as his preceding journalistic career, boasted in a social media post that it was thanks to his own efforts that the protection of “dads’ rights”, to be achieved through the new bill, came to the attention of the minister. Bogdanos claimed he had been alerted to the issue by Nikos Tsilipounidakis, a journalist connected with the Joint Custody Association. Bogdanos called him a “dynamic dad”.

The street campaign turned the pressure up. As the Joint Custody Association was quick to point out to its followers, there was no guarantee that the committee would move in a direction favourable to the association’s demands. 

A poster from the bus stop campaign. The slogan reads:

A poster from the bus stop campaign. The slogan reads: “Joint custody – Equal time with both parents – Shared parenting

Politis Group

These demands targeted what the Joint Custody Association and the other groups considered unjust privileges accorded by the courts to mothers after a divorce, such as exclusive custody over the children. Their proposed solution was for the government to legislate that children after a divorce would by default spend equal time with both parents, within a regime of “shared parenting”, meaning that a child would live half the time with one parent and half with the other. 

Through the efforts of such groups, similar legislative measures, concisely known as “joint custody”, had been pursued by some sympathetic — or misled — politicians over the years, but they never went beyond the stage of an informal meeting, a proposed amendment or at most a draft bill that never left a minister’s desk drawer.  

The danger that the same would happen in this case, according to the Joint Custody Association, lay in the fact that Ioannis Tentes, an emeritus chief prosecutor of the Supreme Court and chairman of the Society of Family Law, was appointed to head the legislative committee. Members of the Society of Family Law, a scientific association of legal scholars, lawyers and judges, some of whom are also former politicians, had previously taken a public position against “joint custody”.

According to official sources, 70% of divorces during 2017 in Greece were consensual. Members of Parliament both for the government and the opposition cited additional evidence during parliamentary discussions on the new bill, which brings the number of consensual divorces up to 86%. Of the remaining 14%, only about half proceed to a full lawsuit and of those only 3% reach an appellate court. It is therefore evident that even if the grievances proponents of “joint custody” have against court decisions are justified, they only concern a very small proportion of divorces that are highly acrimonious.

The start 

While officially they appeared to advocate for the benefits of both parents participating in child rearing, some media appearances and a multitude of social media posts began to reveal that the groups pushing for “joint custody” formed a burgeoning “men’s rights” lobby, representing divorced fathers who believed that the courts had wronged them in awarding custody of the children to their former spouses. 

“There are many dads who pay too much rent for nine months of pregnancy.”

The Association GON.IS., which was approved as a “primary social care” institution by ministerial decision in 2015 and claims that it supports “both parents”, was founded by former members of an older organisation, named SYGAPA that tellingly translates as “Association for Male and Paternal Dignity”. 

Nikos Tsilipounidakis, the journalist who Bogdanos said had enlightened him about “dads’ rights”, famously quipped during a TV interview: “There are many dads who pay too much rent for nine months of pregnancy.”

Increasingly after the summer of 2020, the lobby succeeded in placing more interviews by its representatives in mainstream media, and enjoyed favourable coverage of its positions in articles not only by journalists, but also by psychologists and legal scholars. This was accompanied by increased activity in social media.

Despite the Joint Custody Association’s professed worries about the composition of the legislative committee, two prominent figures of the lobby, Marios Andrikopoulos and Patrina Paparigopoulou, were also appointed as members. Andrikopoulos is a legal director for a major energy company who runs a popular Facebook page, “Act against Parental Alienation“. Paparigopoulou is a law professor and sister of Ioannis Paparigopoulos, frontman of Joint Custody Association, board member of the International Council on Shared Parenting, former member of “Male Dignity” and co-founder of GON.IS.

The legislative committee presented its draft and report to the Ministry of Justice in November 2020. Unbeknownst to the wider public, the majority of the committee’s members had rejected some of the more radical provisions advocated by the men’s rights lobby. (As the minister is not legally obligated to publish the legislative committee’s draft, this only became evident much later — when the minister was compelled to disclose it after the opposition had filed an official request.)  

This led to disagreements within the lobby on whether the proposed bill, which was soon leaked to the press, was worthy of their support. In the event, the Joint Custody Association published its own draft bill in December 2020 and sent it to the ministry, which rejected it.

During an online panel discussion organised by the Joint Custody Association in February 2021, Marios Andrikopoulos claimed that the majority of the committee was intent on “letting the proposal rot away”, and that he and Patrina Paparigopoulou “put up a great fight”.

Still from the Joint Custody Association online panel discussion, February 2021.

Still from the Joint Custody Association online panel discussion, February 2021.

Ioannis Paparigopoulos, who is apparently regarded as the éminence grise of the lobby and had expressed doubts about the leaked bill, retorted that “if the bill that you [Andrikopoulos] prepared is voted in, you still won’t see your children”.

Nikos Tsilipounidakis challenged Paparigopoulos by claiming that they should all support the minister of Justice. “Last Monday,” he said, “I personally called Mr Paparigopoulos and told him that Mr Tsiaras wanted to see him. When I called him, I was in Mr Tsiaras’s office.”

He went on to say that Tsiaras has been facing heavy opposition within his own party, New Democracy, but he was the first minister of Justice in recent years that had agreed to meet with “their group”.

Tsilipounidakis identified the Society of Family Law as the scourge of the new bill, and claimed that “they” (presumably the society) enlisted the help of Giorgos Gerapetritis, the minister of State, to plant doubts about the bill in the Prime Minister’s mind. He claimed that he knew this because he was “virtually present” at a teleconference between Tsiaras, Gerapetritis and Mitsotakis, where the minister of Justice defended his bill.  

Andrikopoulos argued that the spirit of the new law was in the right direction, particularly in providing that the two parents exercise their parental function after the dissolution of marriage “in common and equally”. “You have won,” he said to Paparigopoulos.

Tsilipounidakis also argued that the bill was “a start” and that they should now “organise their attack” during the public consultation process.  

The attack

When the draft was presented for public consultation on March 18, some members of the Legislative Committee protested that it exhibited important deviations from their recommendations. Some of the provisions advocated by the men’s rights lobby had found their way back into the draft, despite the committee not including them. Although legislative committees’ reports are not binding, deviating from them widely when a draft law is reviewed by a ministry is not only less than transparent in terms of who influences the final draft, but also entails the risk of technical mistakes, such as vague or unenforceable provisions, which was one of the issues some committee members protested about. 

Close to 15.000 comments were posted in all articles of the draft bill, the public consultation platform. The Active Dads Association announced, in its memorandum to the Parliamentary Committee, where the bill landed after public consultation was concluded on April 1, that “out of 15.230 comments submitted, 12.289 were IN FAVOUR of joint custody”. And they concluded that “the consultation has spoken loudly and given a popular mandate for a self-evident change”.

The same argument was employed by Kostas Tsiaras, both in an interview and during discussion in Parliament, where he said that a “record breaking number of comments” signalled a “favourable reception” of the bill. 

However, Aggeliki Adamopoulou, an MP for Mera25, disputed the minister’s claim and said that according to an analysis conducted by her staff, one supportive comment had been copied and pasted over 1200 times, while 6 supportive sentences appeared in identical form up to 1400 times. 

“Is this what overwhelming support means?” Ms Adamopoulou said. “Out of 15000 comments, 9200 at a minimum, that is 61%, are copied and pasted again!”

We decided to check the accuracy of these claims by conducting an analysis of the comments on the public consultation platform. The result supports neither the minister’s claim nor that of the Active Dads Association, being much closer to the numbers cited by Adamopoulou, but it also raises significant questions about the vulnerability of the public consultation process. 

Out of 11.500 comments in support of the bill, 63% (more than 7.200) are copies of other comments. The 7.200 copies correspond to only 658 original comments that have been pasted multiple times. Just one of the 658 original comments has been copied and pasted 343 times, while two variations on it have been pasted 358 times (for a total of 701 copies). 

After scraping the comments on the 23 articles of the draft bill (14.814 in total), we trained a machine learning model in order to categorise comments according to whether they were in support or in opposition to the bill. According to our model, within a +-3% margin of error, it does initially appear that out of 14.814 comments, το 77% (approximately 11.500) indeed is supportive, whereas 23% (approximately 3.400) is in opposition. However, out of the 14.814 total comments, only 47% (6.920) are original, whereas 53% (7.894) are copies of other comments. The picture therefore changes considerably if we only take into account original comments and not copies. In that case, the percentage of comments that support the bill falls to 60% and the percentage of those that oppose it rises to 40%. 

Out of approximately 11.500 comments that we estimate to be in support of the bill, 63% (more than 7.200) are copies of other comments, and only 37% (more than 4.100) are original. 

The 7.200 comments in support of the bill that have been copied essentially correspond to only 658 original comments that have been pasted multiple times. For example, just one of the 658 original comments has been copied and pasted 343 times, while two variations on it have been pasted 358 times (for a total of 701 copies).  

Conversely, out of approximately 3.400 comments that we estimate to be in opposition to the bill, 80% (more than 2.700) are original and 20% (about 670) are copies. The 670 copies correspond to 225 original comments.

Our analysis therefore shows that not only the numbers of supportive and opposing comments are more balanced that the minister and the supporters of the bill claimed, but also that:

Firstly, over half of the comments in the public consultation are misleading, being simply repeated up to hundreds of times each.

Secondly, the majority of these misleading comments are in support of the bill.

Thirdly, there appears to have been a major intervention in the consultation, as the volume of the supportive comments that were copied and repeated (over 7.200 or 63%) is enormous.

The criticism

During public consultation, as well as during discussion in the Parliamentary Committee and in the media, the draft bill was heavily criticised by a wide range of experts, organisations, institutions, feminist groups and NGOs, including the United Nations Working Group on discrimination against women and girls and the UN Special Rapporteur on violence against women, its causes and consequences; Amnesty International; Human Rights Watch; the Hellenic Society of Child and Adolescent Psychiatry; the Family Law Society; the gender equality organization Diotima; the Lawyers Committee on Legal Issues of Co-Custody; and Bar Associations across the country.

The overarching issue for those opposing the new law was that it departed from the child-centered approach of previous legislation, prioritising instead the rights of parents. This was particularly evident in its definition of “the best interest of the child” as equal co-custody between parents, as opposed to a provision that it needs to be defined on a case-by-case basis, as required by international law. 

Another major point of contention was that the bill did not limit visitation/communication rights, even if a parent was accused of child abuse, unless there was an irrevocable conviction for the act. This seemed to reflect a view, espoused by men’s rights groups but also shared by some child protection professionals, that many allegations of child abuse are false and are employed by mothers against fathers in order to alienate them from their children. The Active Dads Association highlighted data from a child abuse hotline run by The Smile of the Child, a prominent child protection NGO, that appeared to show that most abuse allegations are made against mothers. And Maria Kaperoni, a clinical psychologist with Ippokrateio General Hospital in Thessaloniki, who supported the new bill in the media and has been cited by men’s rights groups, has said that she has been asked to provide mothers with reports stating that their children are being sexually abused by their father. “Very often,” she claimed, “the accusations are false.”  

Maria Kaperoni speaking to Vergina TV, October 2020

Maria Kaperoni speaking to Vergina TV, October 2020

Giorgos Nikolaidis, a psychiatrist who heads the Mental Health and Social Welfare Directorate at the Institute of Child Health, and an internationally acknowledged expert on the psychosocial support of child abuse survivors, told us that in Greece there is no unified system for recording reported incidents of child abuse and neglect, and therefore partial data and statistics published by individual services or institutions bear little relation to the characteristics of the totality of incidents in society, as they emerge from studies in random segments of the general population. He went on to say that “using such ‘evidence’ to create a certain impression just before a new family law reform is to be enacted, is plainly a communication game, and has no value for designing social policy for families”.  

Critics of the new bill further noted that in Greece, where court delays are a persistent problem, a provision requiring an irrevocable conviction would mean that a potential abuser could remain in unsupervised contact with their victim for a period of up to ten years. 

This was the only part of the bill that was partially amended in the face of expert criticism. After the changes, the visitation/communication provisions made no mention of the issue of child abuse, while the provision about the loss of “parental responsibility” called for a “first instance conviction”.

Further criticism of the new bill focused on both substantial and technical matters, the most important of which were:

  • Τhe bill provides that after separation parents continue to exercise their parental function “in common” and “equally”. The meaning of “equally” (whether, for example, it refers to “equal time”) is vague, which according to opponents of the bill will lead to confusion in the courts. The same provision extends to children whose parents have not married or entered into a cohabitation contract, and were not living together after the recognition of the child by the father. Opponents of the bill pointed out that this essentially awards “equal” custody to a parent — usually the father — who never provided care for the child, without any obligation to prove their suitability or interest.  
  • The bill provides that if the child after separation is living with one parent, then the other parent is by default entitled to visitation/communication amounting to ⅓ of the “total time of the child”. Opponents of the bill pointed out that the term “total time” is vague, as it can be interpreted to mean 8 hours per day, 10 days per month, 4 months per year, or even calculated based on weekends, holidays, and spare time, thus leading to the so-called “⅔ parent” assuming full responsibility for care and the “⅓ parent” becoming a “holiday parent” without responsibilities. Opponents also pointed out that the bill allows the ⅓ parent to actually request less time, leading therefore to a situation where visitation/communication is determined by the needs of the parents instead of the children, contravening international law.   
  • The bill obliges the parent who lives with the child — the ⅔ parent — to inform the other parent — the ⅓ parent — about every decision relating to the care of the child, prior to acting upon it. Opponents of the bill pointed out that this constitutes a violation of the ⅔ parent’s private life, and can be used as a means of harassment or revenge in cases of particularly strained or hostile relations between former partners. 
  • The bill provides that parents have an obligation to “maintain and strengthen  the relationship of the child with the family of the other parent”. Opponents pointed out that this broadens the obligations of the parents towards the child to an unlimited number of other persons, while leaving no room for appreciation of the best interest of the child in relation to its contact with the extended family members of the other parent.
  • The bill makes mediation mandatory, a violation, opponents say, of the Istanbul Convention to which Greece is a party. 
  • The law relies on the “parental alienation syndrome” theory for the determination of the best interest of the child, the description of child care, and the regulation of communication and visitation. Opponents of the bill pointed out that the theory is disputed.

The support

Even before the draft of the new law was revealed, it was evident that the “parental alienation syndrome” theory was employed by the men’s rights lobby as a scientific argument in support of the reform. According to the theory, the “syndrome” occurs when a child becomes alienated from a parent as a result of the psychological manipulation of another parent, particularly in the context of conflictual family separation. Interestingly, during discussions in the Parliamentary Committee, the “syndrome” was not only defended, but presented as the prevailing academic consensus, by Marieta Papadatou-Pastou, a professor of psychology representing the Hellenic Psychology Society. 

Marietta Papadatou-Pastou speaking at the Parliamentary Committee, May 2021.

Marietta Papadatou-Pastou speaking at the Parliamentary Committee, May 2021.

When asked to cite her sources, Ms Pastou pointed to what she calls “the Warshak report”, meaning a 2014 paper by psychologist Richard Warshak, titled Social science and parenting plans for young children: A consensus report. The conclusion of the paper was that equal time spent between parents was beneficial to the child. The “consensus” part of the title was based on the fact that the paper was accompanied by a list of 110 scientists that endorsed its findings. As the paper itself admits, this is “a rare occurrence in social science”. Both for the author of the paper and Ms. Pastou in the Greek Parliament seven years later, this was an advantage of the paper that allowed it to support its claim of offering a “consensus”. In truth, it did not make Warshak’s view any less controversial.

Richard Warshak has picked up the mantle of child psychologist Richard Gardner, who proposed the “syndrome” in 1985. He is considered his scientific successor, so much so that after Gardner’s passing, Warshak inherited his unpublished instructional video and audio tapes from his family. Warshak is the author of a best-selling book titled Divorce Poison and more importantly, he has inspired a business as an applied version of his ideas called Family Bridges, where he holds a role as scientific advisor.

“This so-called syndrome is a communication tool, systematically promoted by various organisations of divorced men. It has never been recognised as an actual clinical entity by prestigious international or national scientific institutions.”

Family Bridges are often called by their opponents “reunification camps”. They are workshops that aim to heal “parental alienation” and repair the relationship with both parents. In reality, according to a series of stories told by outlets such as The Atlantic, NBC and Reveal, multiple testimonies of children that have been through these camps tell a different story, accusing the programme of manipulating them and traumatising their relation with the parent who had custody. An expert was quoted in The Atlantic calling them “torture camps for children”. And since these workshops are quite expensive and mandated by judicial orders, a lawyer involved in a legal battle against Family Bridges told the Washington Post in 2017 that “the programs are basically shams. It was clear to me what they were doing was reaping massive fees by selling a custody change”.

According to psychiatrist Giorgos Nikolaidis, the claim that the existence of the syndrome in question is widely accepted is false. “This so-called syndrome,” he told us, “is a communication tool, systematically promoted by various organisations of divorced men. It has never been recognised as an actual clinical entity by prestigious international or national scientific institutions. Recently, in order to clarify the issue and avoid misinterpretation, the World Health Organisation decided to omit any mention of deprivation of contact with a parent in its most recent revision of the International Classification of Disorders.”

Another source of support for reforming family law in the direction espoused by the Ministry of Justice was the Greek Ombudsman, or Citizen’s Advocate, an independent authority, headed by lawyer and law professor Andreas Pottakis. As early as August 2020, Pottakis addressed a letter to the minister, where he argued for the benefits of “joint custody” and “shared parenting”, citing Council of Europe resolutions of 2013 and 2015 that urged member-states to legislate providing an “option for common custody in case of separation” and introduce “the principle of alternating habitation”.

In May 2021, when the draft bill was being discussed in the Parliamentary Committee, the Ombudsman addressed another letter, this time to the chairman of the committee, Maximos Charakopoulos, where he reiterated his approval of the ministry’s efforts to reform family law, but criticised it for not going far enough in legislating “alternating habitation”.

Yiota Masouridou, a lawyer who also serves as the general secretary of European Democratic Lawyers and a vocal critic of the bill, told us that “the Council of Europe’s recommendations are non legally binding policy agreements which constitute soft law. They are often used for political pressure on governments to act or regulate an issue according to a specific guidance.”

“Lobbies supporting changes on family law, as well as institutions such as the Ombudsman,” said Masouridou, “recall specific extracts from selected CoE’s recommendations, causing, deliberately, confusion over the scope and the context of Greece’s obligations deriving from international law. It should be clarified at all levels that the protection of victims of domestic violence is absolute and does not allow for any measure that protects or covers the perpetrators at the detriment of the rights of the victims.”

According to Nikolaidis, who is also a member and former chairman of the Lanzarote Committee, the Council of Europe body responsible for monitoring the Convention on the Protection of Children against Sexual Exploitation and Sexual Abuse,  there is now a tendency in various European countries to revise “shared parenting” or “alternating habitation” measures, as they are proving “non viable”. 

“The same is true,” Nikolaidis told us, “for international institutions such as the Council of Europe and its various committees: in a recent discussion of the committee for the protection of the rights of children who are deprived of parental care due to divorce or other causes, any mention of such measures was omitted to avoid misunderstandings and misinterpretations.”  

“There is a confusion,” he said, “between the widely accepted benefits for a child of continued contact with both parents and the dubious promotion of the spurious ‘alienation syndrome’ or ‘alternating habitation’ as a general rule. It is one thing to observe that children of separated couples can benefit from quality contact with both parents. But this is achieved primarily by former couples that find a way to communicate for the benefit of their children. To apply findings based on this observation to cases of separated parents in conflictual divorces and legal battles, and to use them to support legal and administrative measures, such as those we saw in Greece, is a leap of logic and a methodological sleight of hand.”

“It is a shame,” Nikolaidis concluded, “that even respected academics, but also institutions like the Greek Ombudsman, have had such a lapse of judgement.”

The split 

In the days leading up to the Parliament Plenary Session debate, the disagreements over the bill that had been brewing within the governing party became public. Two New Democracy MPs, former ministers Marieta Giannakou and Olga Kefalogianni, publicly expressed their objections to the bill, reiterating the main points of criticism that had emerged during public consultation.

Τhe minister of Justice retorted in an interview that the two MPs’ objections were rooted in their “personal experiences,” which was “no way to legislate”. Giannakou countered with the question if the minister would have said as much if the objections had been raised by men. 

The two MPs then went on to file a proposal for ten amendments to the bill, tackling the most problematic points. It was the first instance of such determined opposition to government policy during New Democracy’s two years in office. The ministry rejected the amendments.

During discussion in the Parliamentary Committee, Giannakou criticised the ministry for not meeting with established women’s organisations and excluding them from the dialogue on family law reform. “By contrast,” she said, “we saw improbable organisations, such as GON.IS., Joint Custody, Active Dads, tremendous adverts in support of the bill, which means a lot of money, and an identical letter emailed to us with various names but no actual identification. All these people love their children so much that they can’t write a letter about this issue? Or is it a company, which has the money to send all this with false names? I believe it is the second.” 

Marietta Giannakou speaking at the Parliamentary Committee, May 2021.

Marietta Giannakou speaking at the Parliamentary Committee, May 2021.

At the Plenary Session debate, on May 20-21, the opposition vigorously opposed the bill. There were some differentiations: Andreas Loverdos, former minister and MP for KINAL (Movement for Change) voiced his support for shared parenting. And Elliniki Lysi (Greek Solution), a far-right party, opposed the bill on homophobic grounds, as in their opinion it does not safeguard the traditional family. Although a few more New Democracy MPs expressed reservations about it, notably former minister of Justice Charalambos Athanassiou, most defended it strenuously — some a little too strenuously, as evidenced by one parliamentarian’s opinion that “a woman may hate her ex husband, who cheated on her, beat her and abused her, but still the child has the right to grow up with both parents”.

In an unusual turn of events, at least for parliamentary norms, when the minister of Justice was confronted by criticism that the civil code does not include a provision to the effect that parents exercise their parental function “equally” during marriage, and therefore the bill’s provision that they are to “continue” doing so when divorced is nonsensical, he decided to amend the civil code on the spot, and add “equally” to the relevant article.

It was also revealed during the debate that the United Nations Working Group on discrimination against women and girls and the Special Rapporteur on violence against women, its causes and consequences, had addressed a letter to the Prime Minister on May 17, which was highly critical of the bill and recommended “review and reconsideration of those provisions in the Bill taking into account Greece’s international human rights obligations”. It also requested that its contents “be shared with the Parliament at the earliest”. The government had not disclosed the letter to Parliament, and when confronted with it by the opposition, the Minister of Justice denied knowledge of it. 

The bill was finally enacted on May 21, with opposition parties either abstaining or voting against it. No corrections were made, despite the extensive criticism. The new legislation is the first to radically change provisions regarding the custody of children after a divorce, since the modernisation of family law that took place in 1983.

Barely a few minutes after the voting was concluded, Act Against Parental Alienation, the facebook page run by Marios Andrikopoulos, shared a curious post: a photograph of Grigoris Dimitriadis, General Secretary to the Prime Minister. No explanation was offered.

A photo of Grigoris Dimitriadis, General Secretary to the Prime Minister, posted on the Act Against Parental Alienation facebook page minutes after the bill was voted through Parliament.

A photo of Grigoris Dimitriadis, General Secretary to the Prime Minister, posted on the Act Against Parental Alienation facebook page minutes after the bill was voted through Parliament.

Other social media accounts associated with the lobby celebrated their victory in more overt ways: 

“The battle was triumphantly won, gentlemen,” one post read. “We move ahead according to the basic plan, without a STEP back. We turn our heavy artillery against the judiciary, we load, we lock and we WAIT! Let the members of this group who leak things tell the Union of Judges and Prosecutors that we have them in our sights.”

Data analysis of the comments in the public consultation was contributed by Thanasis Troboukis, a data journalist and Project Manager of iMEdD Lab.