The Council of Europe Explanatory Report of the protocol states "European Court of Human Rights has made it clear that the denial or revision of "clearly established historical facts – such as the Holocaust – [...] would be removed from the protection of Article 10 by Article 17" of the ECHR (see in this context the Lehideux and Isorni judgment of 23 September 1998)".
The Council of Europe's Explanatory Report on the protocol states that "European Court of Human Rights has made it clear that denying or revising "clearly established historical facts – such as the Holocaust – [...] would be removed from the protection of Article 10 by Article 17" of the ECHR (see in this context the Lehideux and Isorni judgment of 23 September 1998)".