climate change

Human Rights and Climate Activism: Italy's response to Communication AL ITA 6/2024 from the special rapporteurs on the case of Valentina Corona

The article examines Valentina Corona case and Italy’s reply to UN Special Rapporteurs, analysing the Bologna protest, the government response and the broader implications for human rights and civic space.
Climate Justice Peace

Table of Contents

  • Background 
  • The reply of Italy  
  • Shortcomings of the Italian reply
  • Contrasting narratives 
  • Conclusions

Background

On 6 December 2024, six UN Special Rapporteurs transmitted a Joint Communication (AL ITA 6/2024) to the Government of Italy. The communication was prepared under the Special Procedures of the Human Rights Council, which allow independent experts to request clarifications from states regarding alleged violations. 

The letter addressed events that took place on 9 July 2024 during the G7 Ministerial Meeting on Science and Technology in Bologna where members of “Extinction Rebellion”  carried out a non-violent demonstration in Piazza Maggiore, chaining themselves to block the access to Palazzo d’Accursio, while others unrolled protesting banners on the facade of the building. 
According to information submitted to the UN, 21 activists were taken to police headquarters, held for seven to eight hours, identified, photographed and charged. Among them, Valentina Corona, described not as an active protester but as a mediator between activists and police, allegedly suffered degrading treatment, including being forced to undress fully, bend over, and being denied access to a lawyer. 

The UN experts warned that these events could violate ICCPR Articles 9, 14, 19 and 21, which protect liberty, fair trial rights, freedom of expression, and freedom of assembly, as well as Articles 13 and 24 of the Italian Constitution on personal liberty and the right to a fair trial. Therefore, they requested a reply from Italy within 60 days, in line with the confidential procedure for communications, but since no reply was submitted by the deadline, the communication was made public on 12 February 2025

The reply of Italy 

Italy provided its formal reply in March 2025, several months after the original communication (AL ITA 6/2024) had been issued by the UN Special Rapporteurs. The document was transmitted by the Permanent Mission of Italy to the United Nations Office and other International Organisations in Geneva. The Italian intent that emerges from the reply is to reframe the Bologna protest as an issue of public safety, with the objective of showing that national legal procedures were respected, and, finally, to reiterate Italy’s international credibility as a state committed to human rights.

Operational Justification 
The first element of the reply is the operational narrative. Specifically, Italy does not describe the facts as an act of symbolic protest but rather as a situation of concrete risk. Moreover, the text insists that the police intervention was triggered not by the content of the activists’ message, but by the strategies used in the protest, which allegedly posed a threat to public safety and order.

Furthermore, the reply constructs a picture in which intervention was indispensable, necessary and proportionate, by stressing that activists chained themselves together, refusing to move; the obstruction of the entrance of Palazzo d’Accursio and the need for the intervention of firefighters to prevent injuries of protesters hanging from the façade of the building. The government underscores that the police aimed to guarantee the smooth functioning of the G7 ministerial meeting, to ensure the safety of the activists, and to protect historic property.

Legal Framing 
The second relevant element of the reply is the legal framing. Italy insists that none of the 21 protesters was subjected to arrest, instead, all were “denunciati in stato di libertà” (reported while remaining free), which is the legal procedure in Italy when individuals are charged with offences, but not deprived of liberty pending trial. 

The reply reports that demonstrators were charged with Unannounced demonstrationPrivate violenceInterruption of public serviceUnlawful occupation of property and Attempted aggravated damage to a historic building. In addition, the text clarifies that individuals were held only for the time required to perform the judicial police functions of identification, photographing, and filing of charges. It also stresses that judicial authorities were promptly informed, therefore reinforcing the argument that due process was respected. By highlighting the absence of any “arrest” procedure, Italy aims to deny the UN’s concern of “arbitrary detention”. In the government’s narrative, what occurred in Bologna was not a deprivation of liberty, but rather a procedural activity that was consistent with national law. 

The Case of Valentina Corona 
The third component of the reply addresses the case of Valentina Corona. The allegations against the police included degrading treatment, forced undressing, and denial of access to counsel.  
Italy rejects these accusations directly. More to the point, the reply states that Ms. Corona was searched “by female staff in suitable premises and in a manner that did not harm, at all, her dignity”. She was not arrested, but, like the others, she was identified, subjected to a search, and then reported in a state of freedom.
The reply adds that Ms. Corona is also a “persona offesa” (injured party) in another proceeding linked to the same protest, in which she filed a complaint. According to the government, however, the prosecutor’s office has already requested the dismissal of her complaint, and the decision has been notified to her.

Policy on Human Rights Defenders 
Finally, the reply moves beyond the Bologna protest to reaffirm Italy’s broader commitments to the protection of Human Rights Defenders. Specifically, Italy recognises the central role of civil society in democratic life; strong support for women human rights defenders, particularly in the fight against gender inequality; the maintenance of regular dialogue with civil society organisations; active cooperation with the UN Special Rapporteur on human rights defenders and support for media freedom, demonstrated by Italy’s membership in the Media Freedom Coalition. By underlining these aspects, Italy portrays itself as a partner and promoter of human rights at the international and national levels. 

Shortcomings of the Italian reply 

The Italian reply is carefully structured and it offers a detailed reconstruction of the protest and the subsequent police intervention, but there are several limitations related to the legal technicalities, degrading treatment allegations, timing and the shrinking space of civic society. 

Legal technicalities
A central element of the reply is its reliance on a legal distinction between a formal arrest and a “denuncia in stato di libertà”.  The implication is that, since no “arrest” occurred, there can be no “arbitrary detention”. However, the risk of this framing is obscuring the concern raised by the UN experts that the individuals were in practice deprived of their liberty for many hours, in a closed environment, under the control of the police, and without guaranteed access to legal support. 

Degrading treatment allegations
On the allegations concerning Ms. Corona, the reply denies that any degrading treatment occurred, stating that the search was performed “in a manner that did not harm her dignity”, but there is no evidence supporting the facts stated. 

Timing
Italy’s decision not to submit its response within the 60-day confidential period meant that the UN communication was published before the government’s version was available and this delay has consequences on the credibility of the reply in terms of reduced transparency.

Shrinking civic space
Finally, the reply is almost silent in the broader context. By presenting the Bologna protest as an isolated issue, it avoids mentioning the structural concern raised by UN experts and civil society for the progressive narrowing of civic space in Italy. While the Security Decree was adopted only in April 2025 and formally approved by the Parliament in June - therefore, after the Bologna protest - its introduction reinforces the concerns raised by UN experts and civil society  Yet, this context is precisely what makes the case of Valentina Corona particularly relevant in a broader framework; more to the point, it is not only about one activist, but about the climate in which climate protests, human rights defenders and civil society actors are operating. 

Contrasting Narratives 

A further element to take into account is the diverging narratives between Italy’s Reply and the UN Experts concerns. As a matter of fact, it is possible to affirm that Italy presents the events as lawful, proportionate, and procedurally correct; while UN experts, by contrast, highlight potential violations of international and constitutional norms, raising the possibility of arbitrary detention and degrading treatment. 
Furthermore, civil society reports emphasise the seven to eight hours of holding without arrest, the denial of legal counsel, and the forced undressing of Ms. Corona. As mentioned above, these claims are not supported by evidence in Italy’s reply, but only by a categorical denial. In addition, the adoption of the Security Decree 2025 heightens concern, as it introduces broader powers to restrict protests and manifestations. 

Conclusion 

The case of Valentina Corona illustrates the tension between two contrasting perspectives. On the one hand, the Italian Government has presented a reply that emphasises legality, procedural precision, and a broader commitment to the protection of human rights defenders. On the other hand, UN experts and civil society reports highlight concerns about the effective deprivation of liberty, allegations of degrading treatment, and broader restrictions on civic space. 
Italy’s response has strengths in specifying the offences applied, and underlining the distinction between arrest and reporting “in a state of freedom”. Moreover, it explains the events in the context of public safety and reiterates national policies supportive of civil society.

However, questions remain regarding the timeliness of the reply, the absence of independent verification of the allegations and the silence on recent legislative developments affecting the right to protest (Security Decree 2025). 

Concluding, this case shows the difficulty of balancing domestic security considerations with international human rights standards and the way in which this balance is carried out shapes perceptions of Italy’s credibility, both at the national and international level.

Yearbook

2025

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Keywords

climate change environment United Nations freedom of assembly and association Italy