Christian woman convicted for offering consensual conversation in abortion facility ‘buffer zone’, ordered to pay £20,000 in prosecution costs

Livia is guilty.
  • Retired clinical scientist and Christian Dr Livia Tossici-Bolt, 64, found guilty this morning at Poole Magistrates’ Court

  • Dr Tossici-Bolt held a sign reading ‘here to talk, if you want’ and did not engage in harassment, intimidation, or obstruction. Her legal defence is supported by ADF International

  • The US State Department this week expressed concern about freedom of expression in the UK, commenting it was ‘monitoring’ her case

Livia is guilty.

BOURNEMOUTH (4 April 2025) – A Christian woman was this morning convicted for offering consensual conversation in a censorial “buffer zone”.

Dr Livia Tossici-Bolt, 64, was found guilty at Poole Magistrates’ Court. Despite finding as a fact that “the sign made no reference to pregnancy, abortion, or religious matters” and hearing evidence from one council officer that “he did not witness her intimidating or harassing any individual”, District Judge Austin ruled that council officers had a reasonable belief that she was in violation of the PSPO.

One of the council officers testified that “he formed the view that [Tossici-Bolt] was in breach of [the PSPO] on several grounds. He considered her pro-life views, his own previous interaction with her, the complaint that had been received and the sign that she was holding.”

In mitigation, counsel for Dr Tossici-Bolt stressed that “The council has not adduced any evidence that she was observed by any service user or any other form of harm…neither is there an identified victim in this case.”

Following the conviction, the Judge sentenced Dr Tossici-Bolt to a conditional discharge and ordered her to pay prosecution costs of £20,000 which must be paid in full by 31 May 2025.

Earlier this week, a US State Department bureau said it was “monitoring” Dr Tossici-Bolt’s case, which is supported by ADF International, and that it was “concerned about freedom of expression in the United Kingdom”.

Reacting to the verdict, Dr Tossici-Bolt said:

“This is a dark day for Great Britain. I was not protesting and did not harass or obstruct anyone. All I did was offer consensual conversation in a public place, as is my basic right, and yet the court found me guilty. Freedom of expression is in a state of crisis in the UK. What has happened to this country? The US State Department was right to be concerned by this case as it has serious implications for the entire Western world."

“I remain committed to fighting for free speech, not only for my own sake but for all my fellow citizens. If we allow this precedent of censorship to stand, nobody’s right to freely express themselves is secure. With ADF International’s support, I will now consider all legal options,” she continued.

Legal Counsel for ADF International Lorcán Price commented:

“Everyone who cares about free speech should care about ‘buffer zones’. A Christian woman has been convicted merely for offering to chat on a public street in Britain. This ruling should show all reasonable people that, beyond the shadow of a doubt, abortion facility ‘buffer zones’ are incompatible with a free society.

“We will now support Livia in considering all legal options.”

Dr Tossici-Bolt was issued a fixed penalty notice for holding a sign that said “Here to talk, if you want” in a censorial abortion facility “buffer zone” in Bournemouth.

She was then prosecuted after she declined to pay it on the grounds that she did not breach the terms of the Public Spaces Protection Order—which bans acts of approval and disapproval regarding abortion—and had the right, protected under Article 10 of the Human Rights Act, to offer consensual conversations. 

The District Judge who gave today’s verdict is the same judge who last October found Adam Smith-Connor guilty for silently praying in a “buffer zone”, in a case which US Vice President JD Vance directly highlighted in his Munich Security Conference speech

With ADF International’s support, Mr Smith-Connor will appeal his conviction in a July trial.

For more details on Dr Tossici-Bolt’s case, find her support page here.

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Top human rights court deems Evangelical church’s appeal inadmissible

Breccia di Roma church in Rome, Italy
  • Italian Christian community forced to pay tens of thousands in taxes or make “structural modifications” to their place of worship to satisfy the authorities’ demands that their space look more like “a conventional church”

  • Represented by ADF International, the church had filed an appeal at the European Court of Human Rights, which has rejected the case

Breccia di Roma church in Rome, Italy

Strasbourg/Rome (March 24, 2025) – In a blow to religious freedom, the European Court of Human Rights (ECtHR) has ruled that the case of Breccia di Roma, an Evangelical church in Rome, is inadmissible. The church, represented by ADF International, had appealed to the Court after Italian authorities classified its place of worship as a “shop” due to its non-traditional appearance, which led to a demand for around 50,000€ in taxes and fines. 

Despite the church’s argument that the modest architecture of its place of worship does not detract from its use for religious practice and that the Italian Tax Agency’s classification violated its right to worship freely, the ECtHR has decided not to intervene. The decision effectively upholds the Italian Supreme Court of Cassation’s ruling, denying the church the tax exemption granted to other religious buildings in Italy. 

“This ruling is disappointing, as it fails to recognize the right of churches to freely determine the manner of their worship. We continue to believe that the government has no right to dictate the appearance of a place of worship."

Court dismissal despite strong legal case 

Even though the church went up to the highest domestic court claiming a violation of its religious freedom, the ECtHR denied hearing the case claiming “non-exhaustion of domestic remedies”. The Court provided no explanation as to why it does not consider the church to have “exhausted domestic remedies,” given that Breccia di Roma has no other domestic avenues left to pursue. The court also rejected the church’s claim of having been unjustly discriminated against, despite two lower instance courts in Italy having ruled in Breccia di Roma’s favor on this matter. The decision is final. Breccia di Roma must now pay tens of thousands in taxes or make “structural modifications” to their place of worship to satisfy the authorities’ demands.  

In recent years, “inadmissibility” has become the most common outcome of any application pending before the ECtHR. The court received 28,800 new applications in 2024, and 34,650 in 2023. At the same time, the court declared 25,990 pending applications inadmissible in 2024, and 31,329 in 2023.  

It is highly regrettable that Breccia di Roma will not receive justice from the European Court of Human Rights.This religious group was unjustly discriminated against because its chosen place of worship does not look like a conventional church in the eyes of the authorities. The small community is now burdened with thousands of Euros in taxes from which other religious buildings in Italy are exempted."

ADF International remains committed to advocating for the protection of religious freedom and ensuring that churches can operate without unnecessary discrimination based on their appearance or practices.

Breccia di Roma can be supported here.  

Case background 

The Evangelical Christian community, Breccia di Roma, which uses a former shop as it’s place of worship, obtained authorization to change the building’s intended commercial use – in part, so that the applicable taxation would align with the religious, i.e. non-commercial, nature of their activities.  

The Italian Tax Agency, however, claimed that the interior architecture of Breccia di Roma’s worship space was not sufficiently religious in appearance. Therefore, it required the church to pay commercial taxes. Despite winning in the lower courts, the Italian Supreme Court of Cassation sided with the authorities. With no further avenues for justice in Italy, the church turned to the European Court of Human Rights, which has now declined to decide their case.   

We don’t make money we bring people together closer to Christ. Granted, our building does not match the Great Synagogue, a mosque, or any of the basilicas in Rome. Also, because our resources are limited, we meet in a comparatively unspectacular building. But why would a state punish us for that? Our church is not worse or less spiritual, just because our architecture is different,” De Chirico asserted.    

Further details on the case can be found here. 

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