First, the applicants are the Reformed Church at X. and Mr. Y., Pastor of the Church, who also acts with Mr. Z., Secretary of the Church, as its representatives. The title suggest that the reformed church is the only applicant, but the text of the decision itself makes clear that there are more applicants: the Church and the Pastor. Both seem to be accepted by the ECmHR as applicants, which is interesting because in later jurisprudence, the Commission and the Court have sometimes discussed to what extent legal persons can invoke Article 8 and 9 ECHR. In addition, both the Church and the Pastor (want to) represent their religious community as a whole, which the Commission seems to accept. Again, in later jurisprudence, both the ECmHR and the ECtHR have been hesitant to accept applications in which claimants defend interests other than their own personal interests.

Second, although in later jurisprudence, the Commission and the Court have been willing to accept economic aspects under the right to privacy (against the express intention of the authors of the Convention), in this case, the Commission makes clear that it will not discuss this case under the right to privacy, but instead under the right to freedom of religion (Article 9 ECHR) and the right to property (Article 1 Protocol 1).

Third, like with application 172/56, although in later times, the Commission and the Court have been hesitant to evaluate laws and by-laws on their merits as such, rather discussing the circumstances of the case, in this matter, the Commission seems not to exclude that possibility. ‘Applicants have not made any submissions in respect of the General Widows and Orphans Act, enacted prior to the Old Age Pensions Act ; whereas, consequently, the Commission does not consider it necessary to undertake any detailed examination as to the compatibility of this Act with the Convention, but, to any extent that the Applicants’ allegations might be based on the same arguments which they have submitted in respect of the Old Age Pensions Act, it refers to its findings set out below,’ then turning to the specific discussion of the merits of the case.