While Article 81 applies to disputes concerning surnames and forenames, restrictions on the use or change of names have often been found to be justified2, given the absence of a uniform approach in the contracting states and the wide margin of appreciation afforded by the European Court of Human Rights3. The Court has accepted that legal restrictions on changing one's name may be justified in the public interest, for example in order to ensure accurate population registration or to safeguard the means of personal identification4, and restrictions on the choice of forenames can also be justified in the interests
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