A French court ruled that unauthorized filming of a farm does not automatically justify removing a video, emphasizing the balance between animal welfare and property rights.
Video uploaded without authorization
On April 20, 2022, the association L214 Éthique et Animaux uploaded a video filmed without permission at Denkavit France, a company that produces animal feed and sells slaughter calves. The video aimed to expose the conditions of calf farming.Company seeks legal action
On May 24, 2022, Denkavit France filed a request for a preliminary injunction to remove the video, ban its use, and demand compensation for damages. The company argued that the unauthorized filming violated its property rights.Court rejects company's requests
On April 22, 2025, the Angers Court of Appeal denied Denkavit France's requests. It stated that the video addressed a matter of general interest, including animal welfare and consumer information about meat production. The court also noted that the filming did not appear to be an intrusion and only showed the interior of a farm building.Legal questions raised
The court addressed two key issues: whether unauthorized filming alone constitutes a manifestly illegal disturbance, and how judges should balance competing rights. It ruled that unauthorized filming alone is not enough to justify removing the video, as it must be linked to an imperative social need.Clarifying legal precedent
The ruling clarified the Realap jurisprudence from October 15, 2025, which had stated that unauthorized filming “may characterize” a disturbance. The Angers Court of Appeal emphasized that a disturbance can only be considered illegal if it meets the criteria of an imperative social need, which requires a full balance of interests.Incomplete balance criticized
The court criticized the Angers Court of Appeal for not fully considering the repercussions of the video’s broadcast. It noted that the court had overlooked the negative reactions on social media and the distress caused to employees by anonymous leaflets. These factors are important in the balance between freedom of expression and property rights.Repercussions as a legal factor
The ruling highlights the importance of assessing the real-world effects of a publication, such as social media reactions and community impact. However, it also raises questions about whether these effects should be attributed to the publisher or to third-party actions, which could affect how courts handle similar cases in the future.Impact on preliminary injunctions
The ruling changes how preliminary injunction requests are evaluated. While lack of authorization remains a necessary condition, it is no longer the sole focus. Instead, the court must weigh factors like health risks, the visibility of the farm, and the effects of the video’s broadcast. This makes the process more similar to a full legal review.
