Profaning a monument (), also translated as insulting a monument, is criminalized by Article 261 of the Criminal Code of Poland, punishable by a fine or restriction of liberty. The law makes no distinction between worthy and unworthy objects of commemoration. A relatively small number of people have been charged under the law, of whom not all were convicted. Law Article 261 of the Polish Criminal Code states in its entirety: "Whoever profanes a monument or other public place commemorating a historic event or honour a person shall be subject to a fine or the penalty of restriction of liberty". Therefore, insulting a monument can only be done deliberately. The crime does not require physical damage to or physical contact with the monument. A separate article criminalizes property damage, otherwise known as vandalism (). One example of prohibited action under the law is "performing activities that are commonly recognised as discrediting the honour or memory of a person or a historic event". Scope of protection The law makes no distinction between worthy and unworthy objects of commemoration (such as Soviet monuments or statues of pedophiles). However, in practice those who insult Communist monuments are not punished. According to Marta Mozgawa-Saj, the law is unclear "whether it is possible to 'desecrate' the monument that 'commemorates persons, organisations, events or dates symbolising communism or another totalitarian system'". She adds that: Cases A relatively small number of people have been charged under the law, of whom not all were convicted. In 2018, Committee for the Defence of Democracy activists hung signs saying "konstytucja" ("constitution") on the Mermaid of Warsaw statue and a statue of former president Lech Kaczyński. They were charged with insulting a monument with regards to the latter incident but not the former. In 2019, proceedings were discontinued because "the accused expressed his political views, and according to the provisions of the Constitution, everyone has the right to do so". On the night of 20–21 February 2019, three Warsaw residents toppled a statue of Henryk Jankowski in Gdańsk; Jankowski was a Catholic priest accused of sexual abuse. One of the accused was a member of Citizens of Poland and an antifascist committee at the University of Warsaw, where he was an instructor. The perpetrators stated in a manifesto that they sought to oppose "the presence of evil personified in the public space, contempt for and objectification of another human being, violation