Catholicos’ decisions not subject to judicial review
Panarmenian.net
Attorney and Mother See legal representative Ara Zohrabyan says the dismissal of Bishop Gevorg Saroyan by Catholicos Karekin II cannot be contested in court.
Responding on Facebook to Saroyan’s recent lawsuit challenging his removal as head of the Masis Diocese, Zohrabyan emphasized that the Catholicos’ decree is not subject to judicial oversight under Armenian law or European legal precedent.
According to Article 61 of the Armenian Apostolic Church Statute, diocesan primates are appointed and dismissed solely by the Catholicos of All Armenians, who acts as their direct superior. Armenian law, including the Constitution and legislation governing church-state relations, explicitly protects the Church’s internal self-governance, Zohrabyan added.
He cited rulings from the European Court of Human Rights (ECHR) affirming that civil courts lack jurisdiction over internal church matters. In one case, a Catholic priest had sued over his removal, invoking Article 8 of the European Convention. The ECHR upheld the Church’s autonomy and found no violation of the Convention, even under Article 6 (right to a fair trial).
Similarly, Hungarian courts had declined to hear a pastor’s challenge against his dismissal, and the ECHR deemed the case inadmissible, reaffirming its prior rulings.
“Under these conditions,” Zohrabyan concluded, “a judge is obliged to reject the claim as inadmissible, as the case is not subject to civil litigation procedures. Otherwise, the Church’s constitutional autonomy would be violated.”
Saroyan is suing to overturn Catholicos Karekin II’s January 10, 2026, decree removing him from his diocesan leadership post, seeking reinstatement via Armenia’s civil court system.

