European legal systems show varied approaches to ministerial immunity and accountability before the law.
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The European Public Prosecutor’s Office request to reform Greece’s system raises broader questions about justice, politics, and equality before the law across Europe. In Greece, criminal liability for ministers is heavily restricted; only Parliament can initiate prosecution with a supermajority vote, effectively granting near-total immunity as judicial authorities cannot act independently. This system conflicts with European law, according to Laura Kövesi of the EPPO. Other countries present varied models: Spain allows special jurisdiction through the Supreme Court, Italy requires parliamentary authorization for prosecution, and Romania has seen increased enforcement against ministers since 2019. Conversely, Bulgaria lacks ministerial immunity but suffers from a politicized judiciary where investigations often target former officials after they become opposition members. The comparison highlights an unresolved European tension between protecting executive function and ensuring public officials are held accountable under the law, making the Greek case a symbol of the Union’s commitment to the rule of law.
