On May 29, 2020, the European Court of Human Rights published an advisory opinion to the Constitutional Court of Armenia on retroactive application of law and whether references to specific articles of the Armenian Constitution within its Criminal Code were “compatible with Article 7 of the Convention.” According to a press release, the Constitutional Court had requested the opinion in its review of a case against Robert Kocharyan, the former president of Armenia, who had been “charged…under Article 300.1 § 1 (Overthrowing the constitutional order) of the 2009 Criminal Code,” but committed the alleged offenses in 2008. Regarding the decision of choosing which Criminal Code to apply in this case, the Court stated that the deciding court must “compare the legal effects of the application of” both and apply the law that was the most lenient. The Court wrote that, according to a review of its case law, “the use of the . . . ‘legislation by reference’ technique in criminal law was not in itself incompatible with Article 7” but that domestic courts had to assess whether “the referencing provision and the referenced provision . . . enable[d] individuals to foresee . . . what conduct would make them criminally liable” given the facts of the particular case. The Court declined to comment on two other questions the Constitutional Court had submitted that lacked a “direct link … [to] the proceedings against Mr Kocharyan.”