The Court of Appeal of Aix-en-Provence stated that its refusal to publish a right of reply from “Non à la Drogue, Oui à la Vie” was unlawful.
by Massimo Introvigne
On 12 March 2026, the Court of Appeal of Aix-en-Provence issued a significant ruling against France’s state-funded anti-cult establishment. This decision overturned a ruling from 2025 that had supported the anti-cult association UNADFI’s refusal to publish a legally required right of reply from the association “Non à la Drogue, Oui à la Vie.” The court’s terms were clear regarding the boundaries of anti-cult rhetoric when it conflicts with fundamental guarantees.
The case began in October 2024, when UNADFI published an article titled “Non à la drogue, oui à la vie : la scientologie ne peut se prévaloir d’avantages fiscaux.” This article included a letter from the Cercle laïque pour la prévention du sectarisme (CLPS), which urged the Ministry of the Budget to review the association’s eligibility for tax-deductible donations. The letter argued that the association openly referenced L. Ron Hubbard, claimed support from Scientologists worldwide, and therefore should not receive tax benefits intended for organizations recognized as serving the public interest. It also cited previous judicial outcomes involving Scientology and the closure of the Narconon center in Burgundy. The letter argued that, because of its perceived connection to Scientology, the association should not have the fiscal status it received.
In January 2025, the association used its statutory right of reply and submitted a text for immediate publication beneath the contested article. This reply defended the association’s mission in the public interest, its work in drug prevention education, its recognition by tax authorities, and its independence from the Church of Scientology. However, Catherine Katz, UNADFI’s director of publication, refused to publish it. She claimed it was misleading, promotional, and irrelevant to the original accusations. The Marseille court agreed with this reasoning in July 2025. It ruled that the reply constituted advertising and that some statements were allegedly false. As a result, the court ordered the association to pay costs and dismissed the request for publication.
Now, the Court of Appeal has fully reversed that decision. The court reaffirmed the legal framework: the right of reply, stated under the 1881 Press Law and the 2004 Law on digital communication, is “general and absolute.” The director of publication must insert the reply unless it is unlawful, abusive, or irrelevant. The court emphasized that denying the publication of a lawful reply is a “manifestly unlawful disturbance” that the référé judge must rectify. It noted that the right of reply aims to allow the targeted person to present their version of the facts, not to determine the objective truth. The judges clearly stated, “the right of reply is not a re-establishment of the truth but a tool allowing a person who has been called into question to give their version of the facts.”
The appellate court then looked closely at the content of both the original article and the proposed reply. It recognized that UNADFI’s publication questioned whether the association could be considered of public interest and thus eligible to issue tax-deductible receipts, given its ties to Scientology. The reply clarified the association’s activities, its recognition by tax authorities, its funding model, and its relationship with Scientology. The court deemed this entirely relevant, stating, “the text proposed by the association must therefore be understood as a response to its being called into question as an association of public interest in light of its links with the Church of Scientology, and not as a misuse of its right of reply for the purpose of promoting itself and/or Scientology. The reply is therefore in correlation with the article in that it does not stray into irrelevant subjects.”
The judgment quoted extensively from the reply to underline its relevance. The court highlighted, “through this reply, the association, which confirms that the French administration has recognized it as pursuing a public-interest purpose and therefore has the right to issue tax receipts to its donors, emphasizes, on the one hand, the social usefulness of its activities focused on combating drug addiction and carried out thanks to contributions from donors, on the other hand, its actions conducted thanks to the commitment of its volunteers and which have benefited thousands of people throughout France, and finally, the fact that it is an autonomous and independent entity from the Church of Scientology in its administration, management, and activities, since the links it maintains with it are essentially moral in nature, such as sharing certain works of L. Ron Hubbard concerning drug prevention and sharing with it certain common humanistic values.”
The court explained why these statements were relevant. It noted that the association was responding directly to doubts raised by UNADFI and the CLPS about its fiscal status. The judges wrote that “in doing so, if the association insists on its socially useful activities and actions, it is to provide clarification on the reasons why it was recognized as being of public interest, and this in response to the article that casts doubt on its right to benefit from the advantageous fiscal framework provided by Articles 230 and 238 bis of the General Tax Code.” The court further asserted that the association had the right to explain that it met the legal criteria for public-interest status, including a social mission, fair management, non-profit activity, and a broad group of beneficiaries.
The judgment also discussed the association’s references to Scientology. It pointed out that the reply mentioned the Church of Scientology and L. Ron Hubbard several times, but only to clarify the nature of the association’s relationship with them. The court wrote, “likewise, if it refers several times to the Church of Scientology, citing it three times, and to L. Ron Hubbard, it is to clarify that the ideas it shares with them (‘certain works of L. Ron Hubbard concerning drug prevention’ and ‘certain humanistic values common’ with the Church of Scientology) in no way undermine its autonomy and independence in its administration, management, and activities, and this in response to the article that challenges its public-interest status granting it fiscal advantages because of its links with Scientology.”
The court then addressed the claim that the reply was false, ruling that “since this assertion does not appear to be entirely erroneous or in contradiction with notorious facts, the association being recognized as of public interest, the illegitimacy of the reply cannot be inferred from a lack of truth, all the more so because the director of publication has the right to add a counter-reply if he or she considers the reply to be incorrect.” This statement directly challenged UNADFI’s attempt to act as the judge of truth and to suppress a reply on that basis.
Having deemed the refusal unlawful, the court ordered Katz to publish the full reply within eight days, imposing a penalty of fifty euros for each day of delay over six months. The court also ordered her to pay three thousand euros in legal costs. This ruling signals that the courts will not tolerate attempts to suppress legally protected replies under the guise of combating “cultic deviances” (dérives sectaires).
The broader context adds more weight to this decision. UNADFI, which gets most of its funding from public sources, has long claimed to be a watchdog against “cultic deviances.” Yet, it has faced repeated critiques for overstepping its bounds and for using its platform to marginalize minority religious or ideological groups. This is not the first time the Court of Appeal of Aix-en-Provence has intervened to correct such actions. In January 2025, it rejected UNADFI’s attempt to stop the publication of a reply from another organization, CAP LC. The court noted that UNADFI’s refusal to publish dissenting views did not justify infringing on others’ rights. The occurrence of these cases suggests a trend in which anti-cult activism often overlooks the procedural safeguards governing public communication.
Thus, this case serves as another instance of the judiciary holding accountable the excesses of anti-cult rhetoric when it violates fundamental rights. It confirms that the right of reply is not merely a privilege granted at the discretion of those who manage the platform but a binding legal obligation. In a climate where accusations of “cultic deviances” often aim to delegitimize minority groups and stifle dissent, the Court of Appeal’s decision restores balance by ensuring that those targeted can speak in their own defense.
Massimo Introvigne (born June 14, 1955 in Rome) is an Italian sociologist of religions. He is the founder and managing director of the Center for Studies on New Religions (CESNUR), an international network of scholars who study new religious movements. Introvigne is the author of some 70 books and more than 100 articles in the field of sociology of religion. He was the main author of the Enciclopedia delle religioni in Italia (Encyclopedia of Religions in Italy). He is a member of the editorial board for the Interdisciplinary Journal of Research on Religion and of the executive board of University of California Press’ Nova Religio. From January 5 to December 31, 2011, he has served as the “Representative on combating racism, xenophobia and discrimination, with a special focus on discrimination against Christians and members of other religions” of the Organization for Security and Co-operation in Europe (OSCE). From 2012 to 2015 he served as chairperson of the Observatory of Religious Liberty, instituted by the Italian Ministry of Foreign Affairs in order to monitor problems of religious liberty on a worldwide scale.
