The whole organisation of the creation of a group of initiators of a referendum (article 14) is too detailed, up to the point that it seems very difficult to combine with the basic principle of free association. In general, it may be said that some people who freely meet may decide, at any given moment, to promote a referendum (which will require, and it should not be forgotten, three millions of Ukrainian citizens’ signatures: articles 3.2 and 13.2). And it is, of course, perfectly reasonable to establish some kind of control on the procedure for that promotion by the public authorities. But the draft departs from a very different point: the purpose of calling for a referendum must be previous to a first “citizens’ meeting” whose degree of public control is probably excessive: previous notification, minimum of participants, place of celebration, written list of participants with all their personal data (full name, date of birth, place of residence…), agenda of the meeting, record of the meeting (with legal specification of the contents which have to be recorded)… All those features imply an absolute administrative (and, therefore, political) control of the meetings, making it highly unlikely to promote any kind of public discussion on issues which may be disgusting for the political power.
