The state is bound to respect the freedom of association1 of its employees, subject to the possible imposition of 'lawful restrictions' in the case of members of its armed forces, police or administration2. This does not, however, mean that state employees are outside the scope of Article 11 protection3, and like the other restrictions on the Article 11 right4, this restriction must be construed narrowly5. However, the requirement for restrictions placed on state employees is simply that it be 'lawful': it appears that there is no need for the restriction to be proportionate (although it cannot be arbitrary) nor
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