Statement on Initiating Criminal Proceedings
To the Prosecutor General of the Republic of Armenia
From: [Full Name of the Applicant]
Citizenship: [Applicant’s citizenship]
Address: [Applicant’s address]
Place of work or study: [Applicant’s work or study address]
Contact phone: [Applicant’s phone number]
Date: [Date of submission]
Statement
I hereby request the initiation of criminal proceedings against Ani Khachatryan, a member of the Yerevan Council of Elders, for committing a crime under Article 329 of the Criminal Code of the Republic of Armenia (“Incitement to hatred, enmity or intolerance”).
On March 25, 2025, Ani Khachatryan, acting in her capacity as a public official and member of the Yerevan Council of Elders, made public statements during a media-broadcast event (via Factor.AM) that clearly exhibit signs of inciting national hatred, enmity, and degrading the dignity of a group of individuals based on their nationality (citizens of the Russian Federation). Specifically, she uttered the following offensive statements:
- “...everything Russian is rotten. Just like them.”
- “Who are Russians to come to my, your, our city and carry out some kind of environmental actions?”
These publicly made statements are aimed at inciting national hatred, enmity, and degrading human dignity on the basis of nationality, which is a clear violation of Article 29 of the Constitution of the Republic of Armenia (prohibition of discrimination) and Article 23 (inviolability of human dignity). Such statements also flagrantly violate Armenia’s international obligations, including Article 20 of the International Covenant on Civil and Political Rights (ICCPR), Article 4 of the International Convention on the Elimination of All Forms of Racial Discrimination (ICERD), and the recommendations and case law of the European Court of Human Rights and the European Commission against Racism and Intolerance (ECRI).
In addition to the criminal legislation, Ani Khachatryan’s conduct constitutes a gross violation of ethical standards for public officials, as outlined in Article 22 of the Law of the Republic of Armenia “On Public Service”, since her remarks undermine public trust in local self-government bodies and damage the reputation of the Republic of Armenia.
Based on the above, I request:
- To conduct an investigation and initiate criminal proceedings based on the facts described;
- To hold Ani Khachatryan criminally liable in accordance with the laws of the Republic of Armenia;
- To inform me of the measures taken, in accordance with the legal procedure.
Attached to this statement are:
- Link to the live broadcast by Factor.AM on YouTube: https://www.youtube.com/live/3hmfBkqoC6A?t=460
- Link to a backup copy of the video in WEBM format: https://drive.google.com/file/d/1bXS3FBkZhcfXEchWLZkaO1pNUlq3jWrK/view
- Transcript of Ani Khachatryan’s statements: https://ani-khachatryan-case.info/p/transcription
- Legal analysis of Ani Khachatryan’s statements: https://ani-khachatryan-case.info/p/legal-analysis
Respectfully,
[Full Name of the Applicant]
[Signature of the Applicant]