Within Europe there has been a much more limited scope of freedom of expression concerning the National Socialist Party . Six European nations , and even Brazil , have outright banned the use of Nazi symbols , like the swastika or the flying of Nazi related flags . Several cases have come before the European Court of Human Rights , including Garaudy v. France and Honsik v. Austria , dealing with the denial of certain events of the Holocaust . The ECHR in both cases declared the denial of the Holocaust , or certain events/methods that occurred in the duration of , to be unprotected by the freedom of expression . The ECHR categorized the denial of such events as hate speech and propaganda for the National Socialist Party , and made clear no such speech would be protected . The decision in Garaudy was cited more recently by the ECHR in Perincek v. Switzerland , which involved a man denying the events of the Armenian Genocide . However , this time the Court ruled in favor of the complainant who called into question the events of the Armenian Genocide . It was determined by the Grand Chamber ( the ultimate appeal court of the ECHR ) that the nature of the speech was not aimed to promote hatred towards the Armenian people through the justification of genocide , but rather called into question whether the events could be categorized as genocide . It must be noted that this decision was not unanimous and dissenting opinions were put forward that saw this speeches intent to insult the victims and felt it should be categorized as unprotected hate speech
Armenian Genocide
Armenian Genocide
BverG v. Rieger