In Špadijer v. Montenegro (31549/18) the European Court of Human Rights stated that Montenegro violated Article 8 of the Convention. The victim, a prison guard who blew the whistle on five of her colleagues for indecent behavior at work consisting in having abusive “physical contact” with female inmates, complained of a violation of her dignity, honor, reputation, and professional integrity. The Court stated that Montenegrin authorities violated their positive obligations aimed at safeguarding the right to respect for private and family life because of "the lack of assessment of all the incidents in question and the failure to take account of the overall context, including the potential whistle-blowing context."

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