Baltic Journal of Economic Studies 120 Vol. 11 No. 5, 2025 This is an Open Access article, distributed under the terms of the Creative Commons Attribution CC BY 4.0 1 Nicolaus Copernicus University, Poland (corresponding author) E-mail: joannamkawa@gmail.com ORCID: https://orcid.org/0000-0002-4201-8028 2 Nicolaus Copernicus University, Poland E-mail: banasiakmarta4@gmail.com ORCID: https://orcid.org/0009-0009-2147-7135 3 State Non-Commercial Company "State University "Kyiv Aviation Institute", Ukraine E-mail: k.v.mozharovska@gmail.com ORCID:https://orcid.org/0000-0001-7414-6078 DOI: https://doi.org/10.30525/2256-0742/2025-11-5-120-125 FORMS OF CIVIL PROTEST AND LAW ENFORCEMENT ACTIONS DURING THE PANDEMIC – THE CASE OF CYPRUS* Joanna Marszałek-Kawa1, Marta Banasiak2, Kateryna Holovko3 Abstract. The World Health Organisation’s declaration of the state of pandemic dramatically changed the daily lives of the entire population. Fearing steadily rising mortality rates, governments took immediate action, including changes in legislation. In the early stages of the pandemic, there was noticeable public approval for the safety measures introduced. However, as the state of isolation continued, a sense of loss of freedom began to grow, and anxiety and social tensions became a point of reference for expressing opposition. The pandemic changed people's perceptions, especially in the face of the increasing suppression of fundamental rights by the authorities. The restrictions introduced began to resemble an attempt at social control, and those who wanted to fight the flawed system were subject to criminal sanctions. The primary aim of this article is to identify the actions taken by demonstrators against the anti-COVID policy adopted by the Cypriot authorities. The text attempts to answer the question: What forms of action did protesters in Cyprus take during the COVID-19 pandemic and how did law enforcement agencies respond to them? The study was conducted using qualitative content analysis and institutional and legal analysis. The point of reference is the information contained in press releases and news reports relating to the conduct of protesters and law enforcement officers during the period under study. Keywords: pandemic, demonstration, police, civil disobedience, breaking the law, Cyprus. JEL Classification: I18, H12, K42, D74, O52 * Funding: This research paper is a result of the research project Civil Disorder in Pandemic-ridden European Union. It was financially supported by the National Science Centre, Poland [grant number 2021/43/B/HS5/00290]. 1. Introduction The crisis caused by the COVID-19 pandemic exposed enormous problems in the healthcare sector. Existing resources proved insufficient to overcome the scale of infections, and shortages in basic medical supplies drastically affected national economies (Volger, 2024). In order to bridge serious cross-border health threats, in June 2020 the European Parliament called for the establishment of a European Health Union (European Commission, n.d.-a). This entity was to be the implementation of the European Commission's priorities for 2019-2024 relating to the promotion of the European way of life (European Commission, n.d.-b). The motivation for establishing the EUH during the pandemic was "a need for further firmer action at Union level to support cooperation and coordination among the Member States, in particular between neighbouring border regions" (Regulation (EU) 2022/2371, 2022). The legitimacy of multilateral cooperation in returning to normality, but also in targeting state policy with respect for citizens’ rights and dignity, should be the most important value. Nevertheless, when it came to regulating restrictions, countries often pursued their own private interests, the legality of which sparked public debate. An example of this is the government of Cyprus, against which the local population carried out a series of acts of civil disobedience. There are several forms of civil disobedience: from protests and boycotts to petitions and flagging official buildings (Amnesty International, 2024). However, demonstrators should be aware of the negative consequences of their actions. In view of the above, disobedience should be considered as passive resistance of a peaceful nature, far from extreme activism, pursuing the public interest and thus winning Baltic Journal of Economic Studies 121 Vol. 11 No. 5, 2025 over the people for a just cause (Maroń, 2022). The use of violence in civil disobedience would distract attention from the real goal, and the meaning of the protest would be overshadowed. The significant rise of mass media has streamlined the communication process, through which worldviews can be expressed and social attitudes and values shaped (Mazur, 2013, pp. 317–319). In general terms, contemporary media "must protect citizens’ rights to obtain information, but for some countries and organisations they have become a tool for establishing political, economic and cultural hegemony" (Batorowska, et al., 2019, p. 127). It is through the media that politicians can reach a wide audience, express their opinions on international issues and, at the same time, build their brand (Adamik-Szysiak, M, 2014, p. 132). The media play a key role in the process of social integration, enabling the creation of communities with similar worldviews (Banasiak, 2025, p. 100). In situations of threat, these groups are able to show solidarity in order to jointly protect constitutional rights and values, opposing a defective system and government. 2. Legal Restrictions The political system of Cyprus is an example of a presidential republic, in which the President is not only the head of state, but also the head of government, elected by popular vote for a five-year term. Legislative power is vested in Parliament, and judicial power, under the provisions of the Constitution, is a separate, independent body (The Constitution of the Republic of Cyprus). Despite the division into two separate regions: the Turkish Republic of Northern Cyprus (recognised only by Turkey) and the Greek south of Cyprus (internationally recognised as the Republic of Cyprus), the political system has not changed the formal constitutional structure. It actually says that the President is usually a representative of the Greek community and the Vice-President represents the Turkish community (Wereszko, 2022, p. 242). The first cases related to the spread of COVID-19 in the Republic of Cyprus were reported on 9 March 2020. Two Cypriots were infected while returning to the country from England and Milan (Knews, 2020a). Less than two weeks later, on 21 March 2020, the Ministry of Health reported the first death in Nicosia (Reuters, 2020a). The pandemic and its far-reaching consequences for the economy highlighted the need for policies to prevent, combat and respond to emergencies. Importantly, the legal structure of the Cypriot constitution (in particular the content of Article 183) does not include threats to public health as grounds for declaring a state of emergency (Kombos, 2020). Therefore, based on Article 188, which states that "subject to the provisions of this Constitution and to the following provisions of this Article, all laws in force on the date of the coming into operation of this Constitution shall, until amended, whether by way of variation, addition or repeal (...), and shall, as from that date be construed and applied with such modification an may be necessary to bring them into conformity with this Constitution" (The Constitution of the Republic of Cyprus, 1960, Article 188), the government of Cyprus decided to apply the Quarantine Act of 1932. On this basis, it was possible to introduce a number of restrictions aimed at limiting the spread of infection. However, it is worth considering how to interpret the limits of the constitution, especially in the context of its flexibility in crisis situations and the hierarchy of individual articles. The continuity of the constitution de facto determines the durability of the state's legal system, which may translate into how political stability is understood. However, this assessment should not depend on a specific political regime. Protest, which by its nature expresses disapproval of specific actions, does not make a state unstable, just as the absence of demonstrations does not mean that a given state can be considered stable (Perlikowski, 2021, p. 237). The quality of governance and the ability to implement adequate legal instruments can give a sense of agency, and the flexibility of the constitution does not prove that the government is dysfunctional. The reintroduction of a colonial-era law became the impetus for the Cypriot government to impose a full- scale lockdown. The law recognised all infectious and contagious diseases as dangerous, which made it possible to declare infected areas and designate quarantine sites, isolation hospitals, as well as buildings and equipment necessary for their operation (Kombos, 2021). Through legislative changes, the Cypriot government decided to introduce the following restrictive measures: – On 28 February 2020, President Anastasiades announced the closure of four crossings connecting the border between the northern and southern territories of Cyprus (Reuters, 2020b); – On 10 March 2020, educational institutions in Nicosia were closed, and on 11 March, a ban on gatherings of more than 75 people was announced (Globaleducationcy, 2020; Cyprus, 2020); – On 14 March 2020, the Ministry of Health announced a ban on entry into the country for non- Cypriot citizens. The restriction did not apply to legal residents, diplomats, registered students and other authorised persons (Medicalxpress, 2020); – On 24 March 2020, a national lockdown was introduced, prohibiting the movement of all citizens, except in cases specified by law, such as going to work, visiting the doctor or the bank, etc. At the same time, mass events and sporting events were cancelled (European Union Agency for Fundamental Rights, 2020). Baltic Journal of Economic Studies 122 Vol. 11 No. 5, 2025 The restrictions announced by the Cypriot government were met with discontent by citizens who felt the consequences of the government’s unlawful actions in their everyday lives. In addition, on 16 March 2020, the Supreme Court of Cyprus suspended the functioning of all courts in the Republic of Cyprus, which led to the postponement of all court hearings until an unspecified date (Lanoli, 2020). This step weakened the image of the judiciary but also became a point of reference for civil opposition in the context of the restrictions imposed. Adding fuel to the fire was the passport scandal, in which Cypriot citizenship was granted to individuals from the criminal underworld in exchange for investments (Kolarz, 2022). 3. Forms of Protest Carried Out Awareness of the existence of a threat cannot be used as a justification for restricting fundamental human rights, both in the context of freedom of assembly and restrictions on movement (Marszałek-Kawa, 2023a). The restrictions introduced are intended to serve the safety and health of citizens, not to be a means of silencing political controversy. Nor can a person be deprived of their nationality, even if this is to protect the life and health of the general public (The Constitution of the Republic of Cyprus, 1960, Article 14). In this context, it is the law enforcement authorities that should ensure respect for and observance of human rights and freedoms in accordance with the European Convention on Human Rights, enabling safe association and movement (Code of Police Ethics, n.d.). A comprehensive analysis of media coverage in Cyprus shows that the protests were mainly a public reaction to the restrictions introduced by the government, which were intended to reduce the mortality rate. They mainly took the form of street protests and marches, including: – Demonstrations in the capital combined with street blockades On 13 February and 20 February 2021, anti- corruption protests took place in Nicosia, in reference to the passport scandal involving the government (Euractiv, 2021). Some of the demonstrators claimed that "the government lost its legitimacy after the passport scandal and is using the pandemic as a reason to stop the protests" (Euractiv, 2021). – Cooperation with other groups On 7 March 2020, two groups of protesters from the Turkish Republic of Northern Cyprus and the Republic of Cyprus gathered at the checkpoint on Ledra Street in Nicosia (DW, 2020). The protest was aimed at opposing the government's decision to close border crossings and create buffer zones to prevent the spread of the virus (Reuters, 2020c). On 24 May and 31 May 2020, anti-racist and anti- fascist groups began protests outside the Pournara reception centre in Kokkinotrimithia, where migrants seeking asylum were being held due to the pandemic (France 24, 2020). – Protests in front of government buildings On 4 November 2021, a group of protesters gathered in front of the Filoxenia Conference Centre, where the Parliament was in session, regarding the new infectious diseases bill (Theodoulou, 2021). On 29 and 30 August 2020, a group of demonstrators protested in front of the Presidential Palace, seeking to abolish the obligation to wear masks. Their actions were correlated with opposition to vaccination and 5G technology. The demonstrators did not comply with the applicable pandemic rules (Knews, 2020d). – Hunger strikes On 7 May, at the Pournara reception centre in Kokkinotrimithia, a hundred migrants organised a protest combined with a hunger strike, opposing government policy and detention in extreme conditions (Knews, 2020b). 4. Response from Law Enforcement Agencies The functioning of law enforcement agencies in crisis situations and states of heightened alert should always be based on peaceful de-escalation measures (Marszałek-Kawa, 2023b). In this context, the use of direct coercive measures should be considered a last resort rather than the simplest way to counter a demonstration. The protest in Nicosia on 13 February 2021 was suppressed by law enforcement officers using water cannons and tear gas (Bangkok Post, 2021). It was also reported that ten demonstrators were arrested and six protesters were fined €300 for violating the ban on public gatherings (Financia Mirror, 2021). The officers' response was criticised by the public for exposing children participating in the march to health risks. The actions taken were justified by the aggressive behaviour of the demonstrators towards law enforcement forces, and the measures taken were considered an adequate response to the demonstrators’ violation of the law (BayNews, 2021). Blocking checkpoints between the northern and southern regions of Cyprus could seem justified from the point of view of preventing the spread of the virus. However, in terms of international law, it violated the fundamental right to freedom of movement. These concerns were also highlighted by the United Nations, which "supports all effective measures to respond to potential threats to public health; however, it is essential that both sides work closely together to ensure a comprehensive response" (UNFICYP, 2020). Immediately after the decision was announced, law enforcement authorities announced that they would use force in the event of non-compliance with the Baltic Journal of Economic Studies 123 Vol. 11 No. 5, 2025 regulations. The protest on 7 March was suppressed with tear gas. An additional obstacle to movement was created by setting up road barriers (Ekathimerini, 2020). The police used persuasion on the demonstrators, threatening serious criminal sanctions for failing to obey government guidelines (Ioannou, 2020). Protests organised in front of the Pournara reception centre in Kokkinotrimithia (both outdoor and indoor) were suppressed by the police with criminal sanctions and temporary arrests (France 24, 2020). In subsequent actions, officers used direct coercive measures in the form of tear gas (Knews, 2020). Public opinion strongly condemned the police's attitude towards migrants. The media commented that "the brutal actions of the police show the lengths to which the Cypriot authorities are willing to go to enforce this unjustified, total ban on demonstrations. They are also part of a deeply disturbing phenomenon in Cyprus, where human rights are systematically violated" (Amnesty International, 2021). 5. Conclusion Civil disobedience is defined as a conscious act of opposition to the existing legal order, the primary goal of which is not to achieve material benefits, but to initiate a change in the way of thinking and in the approach of public authorities. This action should manifest itself in the reorganisation of inefficient policies and laws that particularly affect the protesters' concerns (Lai, 2021). However, it is important that the cause being demonstrated for is not related to party or private interests, and that its goal is to promote the common good (Atilgan, 2020). When interpreting civil disobedience holistically, it should be borne in mind that deliberate and drastic violations of the law are considered extreme activism. For example, on 19 July 2020, a group of protesters vandalised the SigmaTV television station building, setting fire to vehicles and attacking 12 police officers (Aljazeera, 2021). It is wrong to equate such a brutal act with civil disobedience, as actions that threaten the safety of others do not fit within its definitional framework. The actions taken by protesters during the COVID-19 pandemic mainly took the form of street protests. This opposition was directed against the strict restrictions that were intended to cover up the government's terrible decisions, such as the passport scandal. The response of law enforcement agencies, including the use of direct coercive measures, should be considered disproportionate to the actions taken, where "the shocking violence used by the police against peaceful protesters on 13 February constituted an unnecessary and excessive use of force" (Amnesty International, 2021). Both physical and psychological brutality violated the basic ethical principles of police officers. The reactions to demonstrations involving children, where they were deliberately exposed to dangerous substances, were also morally questionable. The pandemic crisis had a negative impact on the economy, but also on the relationship between the state and its citizens. The intensifying protests were aimed at changing the authorities’ way of thinking, particularly with regard to their policy towards reception centres and detained migrants, whose open stigmatisation by the government threatened the foundations of democratic order. References: Adamik-Szysiak, M. (2014). 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