Infringement proceedings against the Slovak Republic for Constitutional Law 255/2025: Primacy of EU law vs. Constitutional Identity

https://doi.org/10.63189/BFLU7994

On September 25, 2025, the Slovak Parliament passed Constitutional Law No. 255/2025 Coll.,^[1] which amended several articles of the Slovak Constitution (Articles 7, 15, 41, and added a new Article 52a).^[2] These changes show a conservative concept of family and national sovereignty in the Constitution.  The main provisions of the amendment can be summarized as follows:

• Parenthood is explicitly defined in Article 41, according to which the parents of a child are the mother and father, where the mother is a woman and the father is a man.^[3] This provision is the normative anchoring of the traditional (primarily biologically determined) model of the family. The aim of the proposers was to constitutionally cement the traditional understanding of parenthood and ensure the stability of family law relationships.^[4]

• Surrogate motherhood is constitutionally prohibited.^[5] The ban, which supplements Article 15(5) of the Slovak Constitution, does not in fact codify a completely new legal status. In the Slovak legal system, surrogacy has been implicitly addressed since 2005 in Section 82 of Act No. 36/2005 Coll. on the family, which stipulates in paragraph (1) that "the mother of the child is the woman who gave birth to the child" and in paragraph (2) adds that "agreements and contracts that are contrary to paragraph 1 are invalid."^[6] This has legally excluded any agreement on surrogacy, whether altruistic or commercial in nature. Of course this was not an explicit ban on surrogacy, which for many years remained in a legal grey zone. The constitutional enshrinement of this principle aims to cement the existing ban as a principle of public order. According to the proposers, the aim of this provision is to protect the dignity of women and children and to prevent the commodification of motherhood, which they see as an unethical practice that violates the natural bond between mother and child.^[7] It is also argued that surrogacy constitutes a form of exploitation of women in need and objectification of the human body. The ban also responds to the growing number of cross-border cases where Slovak couples enter into surrogacy agreements abroad, which subsequently leads to legally complicated recognition of parenthood.

• Adoption of a child is only permitted for married couples of the opposite sex (or, in exceptional cases, for single persons), which significantly limits the possibility of adoption for non-heterosexual couples. Since marriage is defined in the constitution – and has been since 2014 – as a union between a man and a woman, the amendment clearly centers a heteronormative family structure as the constitutional norm for adoption. It bears mentioning that this is not entirely new, this provision had existed prior to the amendment in Slovakia’s Family Act.

• Gender is only recognized in its biologically determined form – the constitution explicitly recognizes only two genders, male and female, thereby denying legal recognition to transgender and non-binary persons. In practice, this means that Slovakia will not legally recognize any gender identity outside the binary male and female genders. A new article (Article 52a) has been added, which states: "The Slovak Republic recognizes only the biologically determined genders of male and female."^[8] Before the adoption of this amendment, the Constitution did not explicitly distinguish between the two sexes, but several of its provisions already indirectly reflected a binary understanding of gender – for example, the protection of women during pregnancy (Article 41(2)), special labor law guarantees for women (Article 38(1)), and the constitutional definition of marriage as a union between a man and a woman (Article 41(1)).

• Sovereignty and supremacy of the constitution: Article 7 of the constitution has been amended to allow Slovak authorities to assess the scope of application of EU law in the Slovak Republic, and in "matters of national identity," the constitution and domestic laws take precedence over international law. In other words, the amendment enshrined the primacy of domestic law in cultural and ethical issues.

These constitutional changes provoked sharp reactions at home and abroad in the fall of 2025. Many hailed the amendment as a protection of fundamental values against external pressures. The amendment was described by Prime Minister Robert Fico as creating a dam against progressivism in Slovakia’s legal system.^[9] On the other hand, critics pointed out that these were discriminatory measures against the LGBTI+ community and a violation of Slovakia's international human rights obligations. On September 24, 2025, the Venice Commission of the Council of Europe issued an urgent opinion warning that references to "national identity" must not lead to discrimination and must remain within the limits of Slovakia's obligations under EU law and the European Convention on Human Rights.^[10] The Commission was asked, through the Monitoring Committee of the Parliamentary Assembly, to prepare an urgent opinion on the draft amendment. In August 2025, the Venice Commission sent a delegation to Bratislava, which met with government representatives, members of parliament (from both the coalition and the opposition), the Public Defender of Rights, the Constitutional Court, civil society organizations, and other stakeholders. The aim of this mission was to gather facts and opinions from various sources. The urgent opinion was published on September 24, 2025, just one day before the planned vote in parliament.^[11] However, it should be emphasized that at the time of its publication, according to the rules of procedure of the National Council, it was no longer possible to intervene in the content of the proposal - the third reading serves exclusively to remove linguistic and technical deficiencies. Shortly before the final vote in the National Council, more than 50 Members of the European Parliament sent an open letter stating that the amendments contravene Article 2 of the Treaty on European Union (values of the Union) and the Charter of Fundamental Rights of the European Union.^[12]

The decisive vote took place on September 25, 2025. The National Council approved the constitutional amendment by exactly 90 votes, which is the minimum number required for the adoption of constitutional law. The European Commission had also warned the Slovak authorities during the legislative process about possible conflicts with EU law. When Slovakia adopted the amendments despite the warnings, the Commission responded with official legal action. On November 21, 2025, the Commission sent Slovakia a letter of formal notice, thereby officially opening infringement proceedings INFR(2025)2208.^[13] In this letter, the Commission stated that the constitutional amendments in question may violate the fundamental principles of EU law, in particular the principle of the primacy (supremacy) of EU law, as well as the principles of autonomy, effectiveness, and uniform application of EU law. In other words, Brussels made it clear that the Slovak constitution – although an expression of national sovereignty – cannot contain provisions that deny the primacy of European law and the guaranteed protection of human rights under EU law. Slovakia was given two months to respond and remedy the situation.

The Slovak government responded negatively. The prime minister, Robert Fico, described these constitutional changes as an expression of sovereignty and stated that he "cannot imagine any international organization dictating to Slovakia how many genders it should recognize and who can or cannot marry."^[14] Government representatives publicly declared that they welcome this dispute and are prepared to defend the new amendment before the EU institutions.

In its immediate response, the Ministry of Justice of the Slovak Republic defended the constitutional amendment as the result of extensive expert work based on a comparative analysis of foreign legal regulations and broad political and academic discussion.^[15] It emphasized that the enshrinement of national identity and constitutional supremacy is a legitimate expression of the state's constitutional authority in the spirit of self-determination and democracy. According to the ministry, this is not a departure from international law or a violation of Slovakia's obligations as an EU member state, and the Slovak Republic remains a credible partner that honors its commitments. The ministry also pointed out that the language of the amendment is deliberately open, and its interpretation will depend on its application in practice and any interpretation by the Constitutional Court of the Slovak Republic. The response was also based on the case law of the Court of Justice of the European Union, which, according to the Ministry, recognizes the concept of the national constitutional identity of Member States, as in the case of Ilonka Sayn-Wittgenstein,^[16] with any conflicts with EU law to be resolved on the basis of the principle of proportionality. The ministry concluded by stating that the amendment protects only those powers that Slovakia has never transferred to the Union and that, within the framework of the transferred powers, it continues to consistently fulfill all obligations arising from the EU treaties.

The infringement proceedings are still in their initial phase. An action before the Court of Justice of the EU under Article 258 TFEU has not yet been brought, and communication between the Commission and Slovakia is ongoing as part of the administrative phase of the proceedings. The Slovak government has not officially published its final response to the Commission. If the Commission considers Slovakia's response to be unsatisfactory, or if Slovakia fails to remedy the alleged shortcomings, a reasoned opinion may follow. This is formally the second stage of the procedure, in which the Commission explains in detail what it considers to be a violation of EU law and calls on the Member State to remedy the situation within a specified period (usually another ~2 months). If the situation is still not remedied, the Commission may decide to refer the matter to the Court of Justice of the EU. The Court of Justice would then issue a judgment on whether Slovakia has breached its obligations under EU law. Given the current divergence of positions, it is likely that the case will reach this stage, i.e., the Commission will bring an action against Slovakia before the Court of Justice in 2026. The government's statements to date suggest a willingness to take the dispute to court.

From the perspective of Slovak domestic law, the Constitutional Court has not yet ruled on this amendment – several opposition MPs have announced that they will file a petition with the Constitutional Court. Theoretically, a paradox could arise if the Constitutional Court of the Slovak Republic declared certain parts of the amendment unconstitutional (e.g., for conflict with the material core of the constitution or international obligations), which could resolve the situation even before the judgment of the Court of Justice of the European Union. For now, however, the core of the dispute is the conflict between the Slovak Constitution (as amended) and EU law.

While the procedure is still ongoing, it shows a clear point of chafing between national constitutional identity and the principle of the primacy of EU law in a member state. Slovakia has attempted to define the red lines of its sovereignty through a constitutional amendment, particularly in cultural and ethical issues such as family, marriage, parenthood, and gender identity. Similar to Hungary and Poland in the past, Slovakia is signaling that it claims the final say in these areas, regardless of EU law. It bases this position on Article 4(2) of the EU Treaty, which requires the EU to respect the equality of Member States, as well as "their national identities, inherent in their fundamental structures, political and constitutional."^[17] The provision on the protection of national identity first appeared in the Common Provisions of the Maastricht Treaty of 1992 under Article F.1.^[18] Its introduction was intended as a response to the case law of national constitutional courts, which had set limits on the application of EU law in order to protect their constitutional orders and fundamental rights. However, the provision did not fulfill its promise and did not become a general clause providing national courts with some leeway to preserve constitutional identity. This is really palpable especially when it comes to newer Member States, where the CJEU has systematically refused to recognize a broader interpretation of national identity by national authorities.

Family law and moral issues have traditionally been seen as the domain of Member States, and the Court of Justice of the EU has indeed confirmed on several occasions that the definition of institutions such as marriage remains within the competence of the states. On the other hand, the principle of the primacy of European law has been a fundamental pillar of the European legal order since the 1960s.^[19] In its opinion on Slovakia, the European Commission emphasized that even a constitutional amendment cannot circumvent a Member State's obligation to comply with the fundamental principles of the Union. However, in recent years, Member States have increasingly questioned the absolute primacy of EU law. The philosophical problem lies in who has the final say – Luxembourg (the Court of Justice) or Bratislava (the national legislature/operationally the Constitutional Court of the Slovak Republic) – on issues that affect the fundamental values and identity of the nation.

In its practice to date, the Court of Justice of the European Union has allowed respect for national identity (e.g., protection of the state language, national symbols, regulation of the state system) but has never allowed a Member State to evade specific obligations under EU law on the pretext of identity. In the Melloni case (2013), it even ruled that Spain could not apply its own constitutional standards to block a European arrest warrant, as this would undermine the unity of EU law – and the Spanish Constitutional Court had to accept this.^[20] It can be expected that in the case of Slovak constitutional changes, if the matter is brought before it, the Court of Justice will confirm the absolute primacy of EU law and will not recognize national identity reservations as justification for violating treaty obligations.

The infringement procedure against Slovakia has a much wider resonance than just the amendment itself. It opens a debate on the nature of the European Union and the limits of the sovereignty of its member states. On the one hand, there is the concept of the EU as a community of values based on the common principles of democracy, the rule of law, and human rights (Article 2 TEU). Member States have voluntarily accepted the obligation to respect these values and to comply with common rules when they joined. On the other hand, the EU is not a federation and in countries such as Slovakia, there is a growing discourse that the EU should be a union of equal nations, where Brussels does not dictate internal value issues. This idea of national identity includes the belief that each country has historically and culturally conditioned traditions (e.g., the definition of family, attitudes toward religion, child-rearing) in which EU institutions should not interfere. While the case right now deals with Slovakia, Slovakia is not alone, we have seen several decisions where the national courts effectively enforced the primacy of their national law. We have seen this in Bulgaria,^[21] Cyprus,^[22] Czechia,^[23] France,^[24] Germany,^[25] Latvia,^[26] or even Slovakia some twenty years ago.^[27] It is exactly in this light that the question of constitutional supremacy takes on extra significance - a principle that's common to all member states and reflects a long tradition of constitutional order as the highest form of legal expression of state sovereignty. The very principle of the supremacy of the constitution cannot be considered controversial – it has been a natural part of the legal systems of almost all EU Member States since the beginnings of modern constitutionalism. The special legal force of the constitution stems from its nature as a legal act of the highest hierarchy, which has regulated fundamental issues of state organization for more than two centuries. Neither the Treaty on European Union nor the Treaty on the Functioning of the EU contain provisions that would abolish or weaken the principle of constitutional supremacy, which existed long before the European integration project began. Upon joining the European Union, Member States did not commit themselves to subordinating their constitutions to EU law, as confirmed by the wording of most national constitutions (including the Slovak one), which emphasize their special status in the legal order, as well as by the extensive case law of European constitutional courts. Although the interpretation presented by the CJEU takes the opposite view, this approach is not directly supported by the wording of the EU's founding treaties.

Similarly, Article 7 of the amended Constitution which states that the Slovak Republic "retains sovereignty, in particular in matters of national identity," does not in itself violate EU law, especially since Article 4(2) of the EU Treaty expressly states that the national identity of Member States, as enshrined in their fundamental political and constitutional systems, must be respected. Interestingly even the CJEU has acknowledged that preserving the national identity of Member States is a legitimate objective that is respected by the EU legal order.^[28] Therefore, it can be concluded that the constitutional amendments fall within the margin of appreciation of the state. Whether they violate any binding legal obligations will ultimately be determined by judicial interpretation. It is also noteworthy that the primacy of the Constitution is by no means new in our legal order. In fact, Article 152(4) of the Constitution has stated ever since its drafting in 1992 that "the interpretation and application of constitutional laws, laws, and other generally binding legal regulations must be in accordance with this Constitution." This has not changed throughout the existence of the Slovak republic as a sovereign state. So the principle of primacy of the Constitution was part of the Constitution upon Slovakia joining the EU in 2004, to which the Commission raised no objections at the time. And, in a sense, the 2025 amendment only explicitly confirms and clarifies this principle.

From a philosophical point of view, the question of where the boundaries of integration lie is raised. If the EU pushes too hard for uniformity on sensitive moral issues, it can lead to ideological neocolonization. With that it becomes clear, that the dispute over constitutional amendment is more than it seems on the surface. It is a clash of concepts about what it means to be a member of the EU in the 21st century.

^[1] National Council of the Slovak Republic. (2025). Draft Constitutional Act amending and supplementing the Constitution of the Slovak Republic No. 460/1992 Coll., as amended. Bratislava: National Council of the Slovak Republic.

^[2] Constitution of the Slovak Republic, No. 460/1992 Coll. (as amended).

^[3] Art. 41(2) of the Constitution:„The parents of the child are the mother and father; the mother of the child is a woman and the father of the child is a man."

^[4] Ministry of Justice of the Slovak Republic. (2025). Dôvodová správa k návrhu ústavného zákona, ktorým sa mení a dopĺňa Ústava Slovenskej republiky č. 460/1992 Zb. v znení neskorších predpisov [Explanatory Report to the Draft Constitutional Act Amending and Supplementing the Constitution of the Slovak Republic No. 460/1992 Coll.]. Bratislava: Ministry of Justice of the Slovak Republic.

^[5] Article 15 is supplemented by paragraph 5, which reads: "Agreements to bear children for others are prohibited."

^[6] Family Act, No. 36/2005 Coll. on Family and on amendment and supplementation of certain acts (as amended).

^[7] Ministry of Justice of the Slovak Republic. (2025). Dôvodová správa k návrhu ústavného zákona, ktorým sa mení a dopĺňa Ústava Slovenskej republiky č. 460/1992 Zb. v znení neskorších predpisov [Explanatory Report to the Draft Constitutional Act Amending and Supplementing the Constitution of the Slovak Republic No. 460/1992 Coll.]. Bratislava: Ministry of Justice of the Slovak Republic.

^[8] Constitution of the Slovak Republic, No. 460/1992 Coll. (as amended).

^[9] Lopatka, J. (2025, September 26). Slovakia amends constitution to promote ‘national identity’. Reuters. Retrieved from https://www.reuters.com/world/slovakia-amends-constitution-promote-national-identity-2025-09-26/.

^[10] European Commission for Democracy through Law (Venice Commission). (2025). Urgent Opinion on the draft amendments to the Constitution of the Slovak Republic (Opinion No. 1255/2025, CDL-PI(2025)011). Strasbourg: Council of Europe.

^[11] Council of Europe. (2025, September 24). Slovak Republic: Venice Commission issues urgent opinion on the draft amendments to the Constitution. Retrieved from https://www.coe.int/en/web/portal/-/slovak-republic-venice-commission-issues-urgent-opinion-on-the-draft-amendments-to-the-constitution.

^[12] European Parliament Members. (2025, September 16). Open letter of EP membership. https://maria-noichl.eu/workspace/media/static/mep-letter-constitutional-amen-68c9604f91298.pdf.

^[13] European Commission. (2025, November 21). November infringements package: key decisions (Press release INF/25/2481). https://ec.europa.eu/commission/presscorner/detail/en/inf_25_2481

^[14] SITA Slovak News Agency. (2025, November 7). Lecture by Slovak Prime Minister Robert Fico cancelled at a school in Poprad; prime minister says vulgar sidewalk writings were not the reason. https://sita.sk/ficovi-zrusili-prednasku-na-skole-v-poprade-dovodom-vsak-podla-premiera-neboli-vulgarne-odkazy-na-chodniku/.

^[15] Ministry of Justice of the Slovak Republic. (2025, November 21). Reakcia na infringement Európskej komisie na novelu ústavy (čl. 7 – nadradenosť práva EÚ) [Reaction to the European Commission infringement on the constitutional amendment (Article 7 – primacy of EU law)]. https://www.justice.gov.sk/aktualne-temy/reakcia-na-infringement-europskej-komisie-na-novelu-ustavy-cl-7-nadradenost-prava-eu/.

^[16] Court of Justice of the European Union. (2010). Ilonka Sayn-Wittgenstein v. Landeshauptmann von Wien (Case C-208/09) [Judgment of 22 December 2010]. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:62009CJ0208.

^[17] European Union. (2012). Treaty on European Union [Consolidated version]. Official Journal of the European Union, C 326, 13–46. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:12012M/TXT.

^[18] European Union. (1992). Treaty on European Union [Maastricht Treaty]. Official Journal of the European Communities, C 191, 1–112. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:11992M/TXT.

^[19] For example: Court of Justice of the European Union. (1963). NV Algemene Transport- en Expeditie Onderneming van Gend & Loos v. Netherlands Inland Revenue Administration (Case 26/62) [Judgment of 5 February 1963]. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:61962CJ0026.

^[20] Court of Justice of the European Union. (2013). Stefano Melloni v. Ministerio Fiscal (Case C-399/11) [Judgment of 26 February 2013]. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:62011CJ0399.

^[21] Supreme Administrative Court of the Republic of Bulgaria. (2023, March 1). Decision No. 2185 in Administrative Case No. 6746/2022 [Judgment on birth certificate and nationality of a child in Pancharevo case].

^[22] Supreme Court of the Republic of Cyprus. (2005, November 7). Konstantinou v. [Respondent] (Case No. 294/2005) [Judgment on procedural/merits issues].

^[23] Constitutional Court of the Czech Republic. (2006, March 8). Pl. ÚS 50/04: Sugar Quotas III [Judgment on the constitutionality of government regulation concerning sugar production quotas].

^[24] Constitutional Council of France. (2011, June 9). Decision No. 2011-631 DC [Decision on the constitutionality of the 2012 finance bill]. https://www.conseil-constitutionnel.fr/decision/2011/2011631DC.htm.

^[25] Federal Constitutional Court of Germany. (1974, May 29). Order BvL 52/71 (Solange I) [Order on the relationship between Community law and constitutional fundamental rights]. Decisions of the Federal Constitutional Court (BVerfGE), 37, 271.

^[26] Constitutional Court of the Republic of Latvia. (2009, April 7). Case No. 2008-35-01 [Judgment on constitutional review].

^[27] Constitutional Court of the Slovak Republic. (2005, October 18). Pl. ÚS 8/04 [Judgment on constitutional review].

^[28] Court of Justice of the European Union. (1996, July 2). Commission of the European Communities v. Grand Duchy of Luxembourg (Case C-473/93), para 35.

References

Constitution of the Slovak Republic, No. 460/1992 Coll. (as amended).

Constitutional Court of the Slovak Republic. (2005, October 18). Pl. ÚS 8/04 [Judgment on constitutional review].

Constitutional Court of the Republic of Latvia. (2009, April 7). Case No. 2008-35-01 [Judgment on constitutional review].

Council of Europe. (2025, September 24). Slovak Republic: Venice Commission issues urgent opinion on the draft amendments to the Constitution. Retrieved from https://www.coe.int/en/web/portal/-/slovak-republic-venice-commission-issues-urgent-opinion-on-the-draft-amendments-to-the-constitution.

Court of Justice of the European Union. (1963). NV Algemene Transport- en Expeditie Onderneming van Gend & Loos v. Netherlands Inland Revenue Administration (Case 26/62) [Judgment of 5 February 1963]. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:61962CJ0026.

Court of Justice of the European Union. (1996, July 2). Commission of the European Communities v. Grand Duchy of Luxembourg (Case C-473/93).

Court of Justice of the European Union. (2010). Ilonka Sayn-Wittgenstein v. Landeshauptmann von Wien (Case C-208/09) [Judgment of 22 December 2010]. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:62009CJ0208.

Court of Justice of the European Union. (2013). Stefano Melloni v. Ministerio Fiscal (Case C-399/11) [Judgment of 26 February 2013]. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:62011CJ0399.

Constitutional Council of France. (2011, June 9). Decision No. 2011-631 DC [Decision on the constitutionality of the 2012 finance bill]. https://www.conseil-constitutionnel.fr/decision/2011/2011631DC.htm.

Constitutional Court of the Czech Republic. (2006, March 8). Pl. ÚS 50/04: Sugar Quotas III [Judgment on the constitutionality of government regulation concerning sugar production quotas].

European Commission for Democracy through Law (Venice Commission). (2025). Urgent Opinion on the draft amendments to the Constitution of the Slovak Republic (Opinion No. 1255/2025, CDL-PI(2025)011). Strasbourg: Council of Europe.

European Commission. (2025, November 21). November infringements package: key decisions (Press release INF/25/2481). https://ec.europa.eu/commission/presscorner/detail/en/inf_25_2481.

European Parliament Members. (2025, September 16). Open letter of EP membership. https://maria-noichl.eu/workspace/media/static/mep-letter-constitutional-amen-68c9604f91298.pdf.

European Union. (1992). Treaty on European Union [Maastricht Treaty]. Official Journal of the European Communities, C 191, 1–112. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:11992M/TXT.

European Union. (2012). Treaty on European Union [Consolidated version]. Official Journal of the European Union, C 326, 13–46. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:12012M/TXT.

Family Act, No. 36/2005 Coll. on Family and on amendment and supplementation of certain acts (as amended).

Federal Constitutional Court of Germany. (1974, May 29). Order BvL 52/71 (Solange I) [Order on the relationship between Community law and constitutional fundamental rights]. Decisions of the Federal Constitutional Court (BVerfGE), 37, 271.

Lopatka, J. (2025, September 26). Slovakia amends constitution to promote ‘national identity’. Reuters. Retrieved from https://www.reuters.com/world/slovakia-amends-constitution-promote-national-identity-2025-09-26/.

Ministry of Justice of the Slovak Republic. (2025). Dôvodová správa k návrhu ústavného zákona, ktorým sa mení a dopĺňa Ústava Slovenskej republiky č. 460/1992 Zb. v znení neskorších predpisov [Explanatory Report to the Draft Constitutional Act Amending and Supplementing the Constitution of the Slovak Republic No. 460/1992 Coll.]. Bratislava: Ministry of Justice of the Slovak Republic.

Ministry of Justice of the Slovak Republic. (2025, November 21). Reakcia na infringement Európskej komisie na novelu ústavy (čl. 7 – nadradenosť práva EÚ) [Reaction to the European Commission infringement on the constitutional amendment (Article 7 – primacy of EU law)]. https://www.justice.gov.sk/aktualne-temy/reakcia-na-infringement-europskej-komisie-na-novelu-ustavy-cl-7-nadradenost-prava-eu/.

National Council of the Slovak Republic. (2025). Draft Constitutional Act amending and supplementing the Constitution of the Slovak Republic No. 460/1992 Coll., as amended. Bratislava: National Council of the Slovak Republic.

SITA Slovak News Agency. (2025, November 7). Lecture by Slovak Prime Minister Robert Fico cancelled at a school in Poprad; prime minister says vulgar sidewalk writings were not the reason. https://sita.sk/ficovi-zrusili-prednasku-na-skole-v-poprade-dovodom-vsak-podla-premiera-neboli-vulgarne-odkazy-na-chodniku/.

Supreme Administrative Court of the Republic of Bulgaria. (2023, March 1). Decision No. 2185 in Administrative Case No. 6746/2022 [Judgment on birth certificate and nationality of a child in Pancharevo case].

Supreme Court of the Republic of Cyprus. (2005, November 7). Konstantinou v. [Respondent] (Case No. 294/2005) [Judgment on procedural/merits issues].