Helsinki Citizens’ Assembly-Vanadzor

PRWB and partner civil society organizations have submitted a joint opinion on the draft law titled “On Making Amendments and Addenda to the Administrative Procedure Code of the Republic of Armenia,” which was published on the Unified Website for Publication of Legal Acts' Drafts on 27.02.2025. 

The draft proposes eliminating the differentiated approach currently applied in the Code regarding the consequences of suspending an administrative act in cases of disputing claims, and the use of interim measures in cases of obligation, performance, or recognition claims. Instead, it seeks to introduce a uniform approach, allowing only the application of interim measures across all types of claims specified in the Code. 

We believe that the proposed amendment violates the balanced approach to administrative justice, creating tools for administrative structures that enable unjustified interference, whereas citizens are deprived of the real opportunity for effective judicial protection. 

The draft Law may result in the reduction of the judicial protection of the citizens, creating additional workload  for the administrative structures and judicial system, while there was no adequate justification by the authors for making such amendments to the Code. 

The opinion is HERE.