Religion, Nation, State, and Anti-Gender Politics in Georgia and Ukraine

ABSTRACT

Under pressure from the European Union and civil society activists, countries in the European Neighborhood made some advancements concerning the human rights of LGBTI people. However, local resistance emerged as the EU advocated for LGBTI rights internationally. This article explores the role of the Christian Orthodox Church in such resistance in Georgia and Ukraine. It argues that as the LGBTI movement was gaining more visibility, the national Christian Orthodox churches turned into major actors opposing LGBTI rights and so-called “gender ideology” and, in both cases, have proven effective in preventing or slowing down the promotion of sexual and gender equalities.

Introduction

During the past decade, the European Union (EU), defining itself as a “community of values,” made the rights of LGBTI¹ people an integral part of the so-called “Europeanization” process (Slootmaeckers 2020). Gender and sexual equalities became a mandatory—albeit declaratory—condition for countries seeking association with the Union. Georgia and Ukraine are among those countries where—mainly thanks to their negotiation of Association Agreements and visa liberalization in dialogue with the EU—laws to prevent and eliminate discrimination, protect women from domestic violence, and promote LGBTI people’s rights were adopted in 2010–2017 (Luciani 2021; Shevtsova 2021). Nevertheless, these attempts to Europeanize domestic gender and LGBTI equality policies in Eastern Partnership (EaP) countries² did not go smoothly. When the EU became more active in promoting the human rights of LGBTI people internationally, in the early 2010s, Russia emerged as a major regional actor dictating a new gender order based on so-called “traditional Christian family values.” With these changes, the topic of LGBTI rights entered the public sphere.

The processes of Europeanization in the former Soviet republics in the European Neighborhood evolved parallel to religious revival and desecularization as a “reaction to the forced secularization of the Soviet regime” (Köksal, Aydıngün, and Gürsoy 2019, 2). In post-Soviet Georgia and Ukraine, the Christian Orthodox churches started regaining influence at the societal and state levels. With the return of religion into the public sphere, Orthodox Christianity in these countries came to constitute one of the core elements of national consciousness, which could not but influence the promotion of gender and sexual equality in these young democracies. While LGBTI organizations and activists were gaining visibility in Georgia and Ukraine, the national Christian Orthodox churches turned into major public players opposing the promotion of LGBTI rights and so-called “gender ideology.”

Unlike the Roman Catholic Church, Eastern Orthodoxy has no central doctrinal authority, as it operates as a communion of autocephalous churches, each governed locally. However, in Georgia and Ukraine, the Orthodox churches have close ties with the Russian Orthodox Church, though in different ways. The Georgian Orthodox Church restored its autocephaly as early as 1917 and was recognized by the Russian Orthodox Church in 1943. In March 1990, the autocephaly of the Georgian Orthodox Church was recognized and approved by the Patriarch of Constantinople. In other words, it has been formally independent of the Russian Orthodox Church since Georgia became an independent country.

The case of Ukraine is more complicated. During Soviet times, Ukrainian churches were part of the Russian Orthodox Church. As the Soviet Union collapsed, the Ukrainian Orthodox Church–Moscow Patriarchate, with the status of an autonomous self-governing church, came under the Russian Orthodox Church’s jurisdiction. In 1992, the Ukrainian Orthodox Church–Kyiv Patriarchate was founded, led by Patriarch Filaret. The Russian Orthodox Church immediately declared this church schismatic. Finally, the Ukrainian Autocephalous Orthodox Church—the church in exile supported by Ukrainian emigrants during Soviet times—was reinstated in 1990. The three churches coexisted independently until late 2018, with the Ukrainian Orthodox Church–Moscow Patriarchate being the most numerous.³ In 2018, after several years of hybrid war with Russia, Petro Poroshenko, then president of Ukraine, supported by the Kyiv Patriarchate and the Ukrainian Autocephalous Orthodox Church, addressed the Ecumenical Patriarch in Constantinople requesting autocephaly for Ukraine. The decree on autocephaly (Tomos) was granted in January 2019, followed by the unification of the Ukrainian Orthodox Church–Kyiv Patriarchate, the Ukrainian Autocephalous Orthodox Church, and a part of the Ukrainian Orthodox Church–Moscow Patriarchate, in what is now known as the Orthodox Church of Ukraine.

The present article explores the role of the national Christian Orthodox churches in the resistance against gender and sexual equalities in Georgia and Ukraine. The cases of Georgia and Ukraine have several important characteristics in common. First, they have for a long time had territorial disputes that escalated into military conflicts with Russia. Second, both countries have strong EU and NATO membership aspirations, which, considering their geopolitical situation, makes relations with Russia even tenser. Third, political and religious elites in these countries still have close ties with political and religious elites in Russia. As pro-Western attitudes have been growing in both countries, numerous politicians and religious leaders have faced the need to distance themselves from the Kremlin while also opposing what they saw as Western interference in national politics. Approaching these two countries from a comparative perspective provides us with a deeper understanding of how geopolitical and cultural context shapes the practices of the national Christian Orthodox churches as major anti-gender actors in the Eastern Partnership countries.

The present article contributes to the literature on anti-gender movements in Europe, Europeanization of the European Neighborhood, and church and ethno-nationalism in Central and East European countries, questioning the effectiveness of the Europeanization of human rights beyond Europe. It argues that the resistance against LGBTI rights by the national churches in Georgia and Ukraine had to change over time, influenced by the geopolitical situation in the region. Such events as the escalation of the military conflict with Russia, on the one hand, and the backlash against gender and sexual equalities in some EU member states, on the other hand, shape the rhetoric of “selective” Europeanization that the religious leaders propose as an alternative to advances with legal recognition of LGBTI rights.

The article is structured as follows. First, I discuss theoretical relevance and introduce the methods and data used. I then contextualize the country cases before proceeding with their comparative analysis. I argue that in the last two decades (2000 to 2022), the Christian Orthodox churches have managed to gain visible influence over policymaking in Georgia and Ukraine as they have become an important element of national consciousness. Though it may seem that the national governments sometimes choose to respond differently to the frames used by the Christian Orthodox churches in Georgia and Ukraine, in both cases, those have proven effective in preventing or slowing down the promotion of sexual and gender equalities.

Promoting Gender and Sexual Equalities in Eastern Partnership Countries: The Geopolitics of Europeanization

During the last decade, the EU has been seen by many as the world’s leading actor in promoting LGBTI rights in the member states and beyond its borders. Correspondingly, more and more authors have been questioning the capacity of the Union to influence the situation with LGBTI rights in countries where societal attitudes toward homosexuality remain rather conservative (Neo 2020; Saltnes 2020; Shevtsova 2020, 2021).⁴ The issue is usually discussed in connection with “Europeanization,” or the processes of construction, diffusion, and institutionalization of [European] rules (formal and informal), procedures, policy paradigms, styles, ways of doing things, and shared beliefs and norms (Radaelli 2003, 30). The evidence from the countries where the EU can promise a substantial political or economic reward in exchange for norm adoption shows that the EU’s conditionality politics does result in compliance (Börzel and Risse 2012; Slootmaeckers, Touquet, and Vermeersch 2016). Further research suggests, however, that in the case of many Central and East European states—including both EU members and those in the European Neighborhood—promotion of LGBTI equality clashes with newly emerged national identity discourses that resonate better with the population (Mole 2016). Some scholars point out that the EU’s pressure on the local policymakers may cause an increase in negative attitudes toward LGBTI people (Mole 2016; Shevtsova 2020). At the same time, there seem to be reasons also to argue that the rise in homophobic attitudes from the side of right-wing groups can function as an important domestic factor enabling gay rights activists to find new frames, build international ally networks, and win new local supporters (O’Dwyer 2018).

By now, quite a few studies have argued that across the countries in the European neighborhood, the Europeanization of LGBTI rights has become a geopolitical issue (Luciani 2021; Slootmaeckers 2017, 2020; Tolkachev and Tolordava 2020). In the post-Soviet space, the last decade (2010–2020) was marked by the annexation of Crimea and the war in Donbas. It began when Russia stepped out as a major regional player dictating a “new gender order” with Orthodox Christian heterosexual family values juxtaposed to European human rights norms (Luciani 2021; Shevtsova 2021). The term “Gayropa” (gay+Europe) was created and popularized in Russian language media. “Gayropa” referred to Europe as a center of norms, strange to Slavic people, such as same-sex marriage or so-called “gender ideology.”

In such a manner, gender and sexual equality became linked to a country’s foreign policy choices—Russia vs. the Western Bloc (implicitly including the EU and the United States). However, this seemingly sharp East–West value divide became more complicated in countries like Georgia and Ukraine, against the background of persisting public support of European integration, growing nationalist sentiment, and aspirations of national Orthodox churches to gain more independence from Moscow (Chitanava 2015, 2016). Anti-LGBTI rhetoric, in popular perception, became strongly associated with the Kremlin. Thus, Georgian and Ukrainian opponents of gender and sexual equality ended up in a position where they could lose supporters by being accused of supporting Russia or rejecting the European choice of the people. The situation became particularly complex for the Christian Orthodox churches, which, since the end of the last century, have been experiencing a revival in both countries.

Mobilized Anti-Gender Resistances across Europe

Scholarly interest in the growing mobilization against gender and sexual equality across Europe has increased significantly in the last several years following the substantial body of the literature on such mobilizations in other parts of the world (Kaoma 2009, 2012; Vaggione 2010). It soon became apparent that anti-gender campaigns should not be interpreted as a national phenomenon. Numerous similarities between forms of mobilization and resistance against “gender,” “gender ideology,” “gay lobby,” or “homosexualization” seemed not to be only a local trend (Kuhar and Paternotte 2017, 4). In some cases, the authors refer to anti-gender campaigns as a coordinated ideological response, geographically rooted yet influenced by transnational networks, to social changes related to (potential) gains by feminists and LGBTI people (Nash and Browne 2019, 5). However, such an approach implies that substantial steps toward equality for LGBT people have already been made. Roman Kuhar and David Paternotte point out that anti-gender movements do not need to be located in relation to another movement (feminist or LGBT rights). They propose to see them not as a response but rather as “preventive means to prevent the development of specific claims” (Kuhar and Paternotte 2017, 256). In countries with few legal advancements regarding LGBTI rights, politicians and other elites can occasionally use “political homophobia” to promote social cohesion and national identities, especially under external political pressure or in an international conflict (McKay and Angotti 2016).

Several studies dealing with resistance to LGBTI rights promotion in newer EU member states addressed the centrality of nationalist and religious discourses (Ayoub 2014; O’Dwyer and Schwartz 2010). Phillip M. Ayoub (2014) argues that the success of such resistances coming from religious institutions depends on the “degree to which the moral authority of religious institutions is tied to the histories of political transition and national identity” (2014, 356). Comparing cases of Slovenia and Poland, Ayoub points out that, because the Catholic Church enjoyed less credibility in Slovenia, it failed to mobilize enough support to oppose the adoption of LGBTI-friendly norms (2014, 356). Conor O’Dwyer and Katrina Schwartz (2010) address the backlash against LGBTI rights in Poland and Latvia, the first being the case of a country where religious groups’ resistance played a central role. In the latter case, right-wing nationalist sentiment prevailed in a secular context. Since their article was published, recent events in Poland have proven that the authors were right when they argued that EU conditionality could no longer compete with the national identity discourse opposing the adoption of European norms in the post-accession context.

The cases of Georgia and Ukraine differ from those mentioned above. On the one hand, the EU still can attempt to use conditionality there, using various economic and political incentives. On the other hand, however, with no clear membership or further approximation prospects against the background of member states in Central and Eastern Europe, where growing resistance against LGBTI rights has been observed recently, opponents of sexual and gender equalities could find new arguments against the adoption of EU norms.

Othering and Identity Building

When it comes to studies of LGBTI politics in the Eastern Neighborhood of the European Union, the concept of geopoliticization and othering are often in the spotlight. The latter is widely discussed as an instrument eagerly used by Russia and the European Union that define themselves through the range of their norms and values as regional powers, as opposed to one another. Scholars working on Russia have written quite a few works on how the European Union is increasingly presented by Russian state officials and state media as “Russia’s Other,” as the Russian government has put forward the “traditional family values” paradigm challenging “Normative Power Europe” (Verpoest 2018, 139; see also Edenborg 2020; Schiffers 2015; Sleptcov 2018). Acceptance or normalization of homosexuality and same-sex relations are portrayed as issues contradicting the set of norms and values at the core of the newly created national identity, replacing the post-Soviet ideological vacuum in the country and building up to what Nikita Sleptcov defines as “conservative heteronationalism” (Sleptcov 2018, 142). On the contrary, the EU’s “Self” identity is produced by positioning Europe as a pioneer protector of universal human rights and LGBTI rights (Slootmaeckers 2020). However, this process of identity construction between the Russian and European Selves and foreign Others is a continuous interactive process of negotiation in which “the agency of the Other is revealed” (Morozov and Rumelili 2012, 28).

After gaining independence in the early 1990s, a similar ideological vacuum in Georgia and Ukraine also needed to be replaced by a new national identity. Both countries declared their pro-Western, EU, and NATO membership aspirations quite early. They have passed through the separation stage from Russia, defining themselves as something that is “Not Russia.”⁵ Nevertheless, having defined themselves as something that “Russia is not,” both countries ended up in a certain “in-betweenness” (Luciani 2021, 4) as various groups within the national borders of these states are in an ongoing discussion of new national identities and their positioning vis-à-vis Russia, the EU, and the rest of the world.

Against this background, the Christian Orthodox church steadily regaining its position at the core of the new national identity faces a complex situation in both countries. The territorial conflicts between the countries made the national churches more cautious about showing solidarity with the Moscow Patriarchate. At the same time, the approximation with the EU shows at least declaratory support of some of the values that Christian Orthodox churches have traditionally opposed. Nevertheless, with the significant political and economic dependence of Georgia and Ukraine on the European Union and Western partners, contesting the European choice of foreign policy would hardly be a wise strategy. The conflict, which has grown more intense since the full-scale Russian invasion of Ukraine launched in February 2022, has influenced the political activity of both the Georgian and the Ukrainian Orthodox churches. As these religious institutions are carving their own spaces in the national political competition, it inevitably has implications for gender and sexual equalities in their respective countries.

Background. LGBTI Rights in Georgia and Ukraine: From Adoption to Implementation

In 2021, the ILGA Europe Rainbow map ranking 49 countries in Europe on LGBTI equality laws and policies put Georgia in the thirty-second position, ahead of such EU member states as the Czech Republic, Lithuania, Italy, Bulgaria, and Romania. Ukraine ended up fortieth, still ahead of Latvia and Poland.⁶ As the summary in Table 1 demonstrates, indeed, during the last ten to fifteen years, Georgia made notable progress in ensuring the legal protection of LGBTI people.

Table 1. Summary of Key Indicators Related to the Situation of LGBTI People in Georgia and Ukraine

	Georgia	Ukraine
Homosexuality decriminalized	Since 2000	Since 1991
Anti-discrimination legislation	Yes, including SOGI*	Yes, not mentioning SOGI
Laws explicitly protecting LGBTI people	Labor Code (since 2006)	Labor Code (since 2015)
Istanbul Convention	Ratified	Signed, not ratified
Same-sex marriages or registered partnerships	No	No
Successful Pride Marches/Marches of Equality	Only attempts	Yes, every year since 2015
Political forces in the Parliament are openly pro-LGBTI	Yes	No
Hate-crime legislation includes SOGI as one of the grounds	Yes (specified in Criminal Code)	Not explicitly

*Sexual orientation and gender identity.

In both countries, almost all major legal changes regarding equality for LGBTI people have been made under pressure from European institutions, and usually in exchange for clear economic and political benefits. Ukraine in 1991 and Georgia in 2000 got rid of Criminal Code articles criminalizing same-sex relations to meet the standards of the Council of Europe and the European Convention on Human Rights. Similarly, in the early-mid 2010s, the governments of the two countries were pressured into the adoption of anti-discrimination legislation that would protect LGBTI people, among others, as one of the conditions for signing an Association Agreement with the EU and receiving a visa-free regime for their citizens (Shevtsova 2021; Tolkachev and Tolordava 2020). However, while the Georgian government fully met the requirements of the EU and listed sexual orientation and gender identity as grounds protected from discrimination, the government of Ukraine insisted on deleting them from the law. Despite harsh criticism from the EU, the government of Ukraine refused to introduce any changes to the law in this regard. At the end of 2021, the law still did not grant explicit legal protection to LGBTI people. The Labor Code was amended in both countries, with sexual orientation and gender identity (SOGI) being added there to meet the standards of the European Union (Luciani 2021; Shevtsova 2020). However, in both countries the Constitution defines marriage as the union between a man and a woman. While there is an ongoing discussion of the possibility of introducing registered partnerships for same-sex couples (Ukraine even had a project of a law on same-sex partnerships included in its National Human Rights Strategy 2020), it has never been a real prospect.

While ILGA Europe mostly evaluates countries based on existing legislation, the few studies written on LGBTI rights in post-Soviet countries show that the adopted legislation is not necessarily reflected in the real situation for the LGBTI community (Buyantueva 2020; Tolkachev and Tolordava 2020). Neither in Georgia nor in Ukraine is it possible to observe the implementation of anti-discrimination legislation favoring LGBTI people. Since the adoption of those laws, there have been no court cases on discrimination against individuals based on their sexual orientation or gender identity. Moreover, the legislative process in both countries was accompanied by an almost explicit promise by the governments that implementation would not necessarily follow (for more details on the case of Georgia, see Tolkachev and Tolordava 2020).⁷ In 2019, the government refused to provide security forces to protect the peaceful Pride march and ensure the freedom of assembly for LGBTI people in Georgia. The Georgian prime minister, Mamuka Bakhtadze, referred to the Pride events as “artificially forced on Georgian society” and claimed that the issue of homophobia in Georgia was “exaggerated,” as the country had all the corresponding legislation protecting human rights. The refusal to allow holding Pride in Tbilisi due to “safety concerns” was also considered a part of such “protection” (OC Media 2019). In Ukraine, the leader of the major party, Yuriy Lutsenko, commenting on the adoption of the nondiscrimination amendment to the Labor Code in 2015, which had to be put up for a vote six times before the parliament could finally pass it, had to stress that the alternative to passing the law would be Russian tanks on the streets of Kyiv (Shevtsova 2020).

In both countries, the national governments presented anti-discrimination and LGBTI-friendly legislation and policies as something imposed on their countries to meet Western partners’ requirements rather than societal demands. This representation of conservative society may be true to some extent; according to recent surveys by the National Democratic Institute, 27 percent of the Georgian population in 2019 and 43 percent of Ukrainians in 2020 saw discrimination against LGBTI people as a problem (Fabbro 2019). In Ukraine, one may say that LGBTI people enjoy more visibility: since 2015, the country has been hosting a state-protected March of Equality in Kyiv, the capital, and from 2019 to 2021, marches took place in other major Ukrainian cities. This was impossible in Georgia due to the state’s refusal to protect LGBTI people from threats coming mostly from right-wing radical groups. These groups are the cause of most homo- and transphobic violence and aggressive protests in both countries. At the same time, the position of the church, as the following sections will show, has always been to condemn violence and distance itself from the right-wing groups’ attacks. While radical nationalists much more often make it into the news for their resistance to LGBTI rights in Georgia and Ukraine, this paper argues it is the national Orthodox churches that play the key role in preventing the adoption and implementation of LGBTI-friendly laws in those countries.

De-secularization of post-Soviet Countries: Role of National Christian Orthodox Churches

In Georgia and Ukraine, religion and new, post-Soviet national identities became strongly intertwined, especially since both countries found themselves in military conflicts with Russia. According to the Pew Research Center, most people in these countries embrace religion as an element of national belonging even while not being highly observant (Pew Research Center 2017). Most Georgians refer to their national church as one of the prime symbols of what it means to be Georgian; against the backdrop of the annexation of Crimea and war in the east of Ukraine, for many Ukrainians an autocephalic church became critical for confirmation of their national independence (Chapidze and Umland 2019).⁸ As nationalism has gained centrality in Georgian and Ukrainian public discourses, so has the church. By 2020, according to surveys, the church had nearly the highest level of trust among Ukrainian citizens—63 percent, the same as volunteer organizations and only slightly less than the Armed Forces of Ukraine (65 percent).

On the contrary, 49 percent of the citizens responded that they did not trust the president, 75 percent did not trust the Verkhovna Rada, and 77.5 percent distrusted the judicial system (Razumkov Center 2018). In Georgia, the Georgian Orthodox Church (GOC) experienced a “great revival” under the guidance of Patriarch Ilia II, who became the head of the GOC in 1977. Since then, the number of churches in Georgia has increased from 30 to 2,000. As of 2020, the Patriarch remains the most trusted public person in Georgia according to national surveys, with 89 percent of respondents confirming their favorable opinion of him (the next person on the list, Amiran Gamkrelidze, director-general of the National Center for Disease Control and Public Health, got 74 percent, and prime minister Giorgi Gakharia 63 percent). The church also enjoys high support among institutions, at 85 percent, with only the army getting slightly more at 89 percent (International Republican Institute 2020).

With such growing popularity, it is hardly surprising that the involvement of the church in national politics has increased steadily. In November 2016, and soon after, in February 2017, representatives of the GOC traveled to Brussels to meet with NATO and EU representatives. According to the official message from the spokesperson for the Patriarchate of Georgia, the goal of the meetings was to discuss the importance of European integration and the shared values of the European Union and Georgia. Later in the interviews, the representatives of the church commented to the journalists that the trip “put an end to false allegations that NATO was demanding from Georgia to legalize same-sex marriages” (Gamzemlidze 2016). It is worth noting that the first visit in 2016 was followed by the visit of Patriarch Ilia II to Moscow to meet Patriarch Kirill, the head of the Russian Orthodox Church. Unlike the Russian state, the Russian Orthodox Church recognized the Georgian Church’s jurisdiction in Abkhazia and the Tskhinvali region, disputed territories that Georgia considers occupied by Russia. Russia is among the few countries that recognize these territories as partially independent. This is why Tbilisi sees relations between the Georgian and Russian Orthodox churches as the main chance for the two states to improve their relations. The visits to Brussels and growing contacts of some clergy representatives with EU institutions sent a signal that there was no unanimity within the GOC regarding strengthening of relations with Moscow no matter what.

In Ukraine, the Ukrainian Council of Churches and Religious Organizations (UCCRO), established in 1996 as an interfaith institution “aiming to unite the efforts of various denominations to focus on the spiritual revival of Ukraine,” has been gaining power. It includes 16 churches and religious organizations, the Orthodox Church being the most prominent one, and claims to represent more than 90 percent of all religious organizations in Ukraine. Though UCCRO is more than 20 years old, it became particularly active only in 2013–2014. In 2013, when President Viktor Yanukovych’s government ended up between a rock and a hard place, as the refusal to sign Association Agreement with the EU led to the series of events culminating in the most massive anti-government protests in the modern history of Ukraine, representatives of UCCRO made several visits to Brussels. They allegedly reconfirmed “Ukrainian society’s European choice while also defending the traditional view of family and marriage, based on religious, moral values” (https://vrciro.org.ua/en/council/info). Later, in 2014, UCCRO also organized meetings with Russia’s religious leaders to “convey the true view of the events in Ukraine and prevent further escalation of the conflict in the Donbas region, which began due to Russian military aggression.” During the past decade, the leaders of UCCRO have held regular meetings with Ukraine’s presidents and prime ministers and the leaders of relevant governmental bodies and parliamentary groups.

To summarize, for both Georgia and Ukraine the past 10–15 years had become a period of desecularization during which the national Orthodox churches, in Georgia a bit earlier than in Ukraine, managed to gain some political power largely due to the growing nationalist sentiment in these countries, with the national Orthodox church becoming somewhat of a symbol of new national identities. However, in the new geopolitical context, both churches face the need to reinvent themselves as modern political actors involved in the complex value conflict of “Europe” vs. Russia and “European” vs. “traditional” values. As the analytical sections below demonstrate, these national Orthodox churches see a possible solution in “selective” or “alternative” Europeanization whereby only some European norms and policies are adopted and embraced by their respective countries. The rest, such as LGBTI rights or comprehensive sexuality education, will be rejected.

Method: Qualitative Frame Analysis

I have used qualitative frame analysis based on critically informed textual analysis for the present study. In doing so, I have drawn on the idea that framing is a deliberate and conscious work carried out by political actors. Frames are “symbols” crafted intentionally to activate larger discourses and to place a particular social phenomenon (for example, promotion of gender equality or LGBT rights advocacy) in a particular light (Lindekilde 2014, 204). As I have chosen three frames around which the analytical part of this article is structured, I analyzed the selected materials to see how specific texts produced by the national churches either challenge or reproduce established definitions and understandings of social reality.

The collected data included written documents available online through official websites and social media pages of the religious institutions, interviews in national and international media, and relevant statements. It covers documents from 2014 to 2021, when the most active contestation of LGBTI rights promotion in Georgia and in Ukraine by the Christian Orthodox churches took place. I collected 64 written documents in Ukrainian, Russian, Georgian (translated with the help of a native speaker), and English concerning LGBTI equality, anti-discrimination laws, Pride marches, sexual education, homosexuality, and other related topics. The materials were then segmented into phrases and their constitutive parts/sentences to read the frames. As 22 publications with the most consistent textual parts on LGBTI rights, gender (ideology), and sexuality were selected, three main themes/frames became apparent.

I argue in this article that both churches employ for the mobilization of resistance against gender and sexual equality several broader frames:

• Freedom of religion and human rights

• Protection of minors

• Orthodox Christianity as an integral part of “good” nationhood

• Alternative Europeanization

In what follows, I present my findings structured around these frames. Further, I traced what of those frames were reproduced by the national governments and how some found reflection in political steps (or a lack of those).

Human Rights Frame: Protecting the Believers

The opposition to LGBTI equality growing from the Orthodox churches in Georgia and Ukraine is presented as fundamental resistance to specific norms related to gender, family, and sexuality and the conceptual vision they are based upon. Such resistances move away from traditional church rhetoric of “sin” or “deviance.” Instead, the resistance is framed as a question of freedom of religion and expression and state attacks on its citizens. However, this reframing does not change the perception of non-heterosexualities as deviant and not healthy.

The attempts to fight discrimination of individuals based on sexual expression and gender identity are presented as resulting in another form of discrimination—in this case, against people who believe that homosexuality cannot be tolerated. For example, as an official response to the discussion of the anti-discrimination law in Georgia, the Patriarchate issued the following statement:

The EU represents a diverse space unifying different nations and religions, which declares that it recognizes the culture and traditions of various people and is ready to consider and respect our values. However, provisions of this bill conflict with these principles. […] Introduction of a notion of “sexual orientation” and “gender identity”—non-existent in the Constitution—into this bill, essential for the development of our country, triggers massive anxiety in the people because the personal rights of our citizens are already equally protected by the existing Georgian legislation. […] We respectfully ask the Georgian Parliament to postpone the adoption of the bill in its present form and to secure engagement of the Church and the broader public in its discussion in order to reach an agreement and in order not to let hasty actions to have a negative impact on our country’s European aspiration. (Civil Georgia 2014a; my italics—M.Sh.)

Despite this resistance, the Georgian parliament adopted the Anti-Discrimination Bill with 115 votes in favor and zero against less than a month later, on May 2, 2014. A day earlier, Georgian parliament speaker Davit Usupashvili commented that the law’s adoption was a question of foreign policy and national identity choice. The government had to decide whether to go toward “civilized Europe” or toward Russia, “where it is possible to expel people whom you dislike from a city” (Janashia 2014).

The episode with the law’s adoption serves as a demonstration of several points. First, it shows that apart from the standard set of claims appealing to Christian values and heterosexual families, the GOC has appropriated the language of human rights and freedoms. Moreover, there is a reference to the importance of the country’s European aspirations, which are implicitly, and with reservations, supported by the church despite its long-maintained close ties with Russia. At that point, the church could not prevent the adoption of a law that was much needed for the association with the EU. However, one can draw a conclusion on the central role of the church by reading the words of the EU Commissioner for Enlargement and European Neighborhood Policy, Štefan Füle. He met Patriarch Ilia II in Tbilisi two months before the law was adopted and assured him that this was not “an attempt by western countries to impose foreign values on Georgia.” Füle further said, “I have heard it said that the Association Agreement would force Georgia to allow same-sex marriages. There is nothing at all in the Agreement that would force Georgia to adopt any such legislation.” To that, the Patriarch responded that while the church supported the European choice of Georgia, “the EU should take into consideration Georgia’s “traditions and mindset” (Civil Georgia 2014b).

Among recent examples from the Ukrainian Orthodox Church is the successful campaign of the UCCRO against bill 5488, which has not been adopted. The proposed law, among others, proposes an amendment to the Criminal Code of Ukraine to include sexual orientation and gender identity as protected grounds against hate crime. In the official statement published by the UCCRO in June 2021, the Council expresses concerns that “fighting the discrimination can lead to the oppression of freedom of religion, freedom of speech and expression.” This concern is related to the fact that after the adoption of the law, the churches will not be able to refuse an LGBTI person or a woman the right to be employed by religious institutions (for example, women would be allowed to serve as priests, which goes against Orthodox Christian beliefs). The law also “violates the freedom of expression,” since religious leaders will not be able to “criticize same-sex partnerships as immoral and sinful.” The statement finishes with the claim that:

Promoting the problematic bill 5488, the government and the parliament can provoke the indignation of millions of believers of various confessions that do not accept the imposition of gender ideology upon the Ukrainian society and will not tolerate attacks on freedom of religion and expression. There is a high risk of civil protests in this situation.” (UCCRO 2021; my italics—M.Sh.)

Core to these frames of resistance to LGBTI rights promotion, similarly for the two countries, is the “imposition” or “invasion” of dangerous and undesirable values upon the society. These frames also appeal to the state crossing public spaces and interfering in the affairs of the church as an employer (and in the area of private business as well) and even in the private spaces of homes.

Protecting Minors and the Family Frame

Protecting the family and, in particular, minors from a dangerous ideology that may confuse them and impose on them a “wrong” understanding of what a family is supposed to be is the core argument of the resistance in both countries, which, unlike the previous frame, is widely picked up by political parties and seems to be most undesirable for the more liberal political parties to mess with.

Separating the church from education and normalizing the idea of homosexuality in schools is seen by the UCCRO as “experiments over children” that are beyond their families’ control, aimed at promoting “gender ideology” at schools and giving children “wrong” ideas of what sexuality is supposed to mean in their lives, what sexualities are society-approved and state-sanctioned and what is deviant and unacceptable. In the materials in UCCRO’s official media (Vseukrainski Sobor), the authors refer to alleged research results proving that in the Western countries with a more “liberal” approach to sexuality education, higher rates of “gender deviations” as well as suicide and depression among teenagers have been reported. The children, therefore, are to be protected against such harmful influences and turn schools into a “safe space that makes impossible imposing on children the idea of ‘normalcy’ of homosexuality and other sexual deviations” (Sobor 2021).

The solution, according to UCCRO, is in their resistance, appealing to the government to withdraw from international obligations that are threatening Ukrainian families and the Ukrainian nation by disrupting traditional educational practices. Otherwise, the consequence, according to the UCCRO, would be the following:

We see examples of other countries where the people did not stand up for their children’s education. We see that spiritual and pro-family curriculum has been replaced by sexuality education for first grades, where from the very beginning, children are being offered what is called “education” but, in fact, is propaganda of masturbation, sexual experiments, various sexual deviations, LGBT, transgenderism, change of gender, and so on.” (Sobor 2021)

The frame of protection of the institution of the heterosexual family has also been widely used for mobilizing supporters in Georgia. In 2014, the Patriarchate announced the Day of Family Purity in Georgia for May 17 (the same date as IDAHOT, the International Day against Homophobia, Transphobia, and Biphobia).⁹ That year the church organized a rally in the center of Tbilisi attended by several thousand people in support of “family values.” Since then, the Family Purity Days have been held annually, and apart from the counter-rally, this date is celebrated by mass weddings of heterosexual couples in churches across Tbilisi. In a statement regarding this celebration in 2019, the Patriarchate stressed that it was a peaceful expression of the “community’s support towards traditional values” and that they were distancing themselves “from any kinds of violence” (Orthodox Christianity 2019).

This is yet another “contribution” of the GOC to the demographic situation in the country. In 2007, observing the declining birth rate in Georgia, the Patriarch promised to baptize personally any child born to a family where there were already at least two other children. To arrange the baptisms, mass ceremonies have been conducted since then. According to church officials, Ilia II deserves credit for a national baby boom, as by 2020, he had more than 40 thousand Godchildren.

Such frames met more support among politicians. Many politicians seem to have avoided addressing homophobic and transphobic violence in their countries while supporting the framework of “family values” and the importance of religion. The Georgian online media magazine Tabula quotes Gedevan Popkhadze, a Georgian Dream member of parliament, saying, “The Day of Family Purity and the tolerance day [IDAHOT] are valuable for me. […] May 17 is both. […] Tolerance, for me, is that you should respect different opinions, whereas family is the inner world, where people form as persons” (Tabula 2017).

The fear for children’s mental health and the interest of minors is also a regular topic. An example is the Georgian Patriarchate’s statement against the Tbilisi Pride March: “The march of dignity has nothing to do with dignity. It leads to confusion in understanding human values and purposeful distortion of the content that harms the mental condition of minors and damages their interests” (GOC 2021). In 2016, with the support of the GOC, the ruling Georgian Dream coalition in the Georgian Parliament initiated constitutional amendments whereby marriage would be considered only as a union of a man and a woman. The Georgian Patriarchate supported this with an official statement. According to the statement, the amendment was “in the interest of the absolute majority of Georgian citizens regardless of their ethnic or religious group.” Even “sexual minorities would also benefit, as eventually [thanks to the law], the risk of violence against them would decrease” (Chitanava 2016). The amendment entered into force in 2017.

The idea of a family—fixed now in the Constitutions of both countries as a heterosexual option only—being in need of protection became the main common theme between major Georgian and Ukrainian political parties and the Orthodox churches. Both countries now witness regular Family Festivals in which religious communities and conservative politicians participate. The idea of the family presented at such festivals is a White, Orthodox Christian, heterosexual Georgian or Ukrainian couple with children.

Though the idea of family values and protection of minors is central to the Russian anti-LGBT discourse, and the law adopted in Russia in 2012 that bans “gay propaganda” in the country is focused on the protection of minors, this framing of prioritizing heterosexual families and protecting children from the detrimental influence of liberal “gender ideologies” is very popular even in the countries where same-sex marriages and adoption by LGBTI people is legal (see, for example, Nash and Browne 2015, 2019). This frame for resistance, therefore, might be seen as one of the most secure to use; it seems to be quite effective, too, as, in neither of the two countries has comprehensive sexual education¹⁰ been allowed in schools and any educational activity for minors related to the topic of homosexuality or trans people is for now impossible.

Religion and Nationhood Frame

The third frame that both churches are widely using is one that brings together religion and nationhood. Being a good Georgian or a good Ukrainian means being a Christian and sharing the same values. The preservation of these values is tied to the idea of the territorial integrity and “survival” and “health” of the nation.

The GOC’s usual rhetoric regarding LGBTI identity is built around the idea that homosexuality in a way presents a threat to the Georgian nation, that this is something that “Georgianness” cannot include and something that “cannot be compatible with Georgian values and religious identity” (Saralidze 2015). In 2013, on May 17, a group of activists led by GOC clergy attacked a smaller group of LGBTI activists and allies planning to celebrate IDAHOT. Surprisingly, numerous politicians in Georgia did not condemn the violence but accused LGBTI activists of being provocative. One of the parliament members from the Georgian Dream party, Zakaria Kutsnashvili, blamed the excessive visibility of the LGBTI movement, commenting that they went against a large part of the society whose “Georgian identity historically developed as an ethnos, one of the characteristics of which is its religiousness, Orthodox Christian religiousness” (Tolkachev and Tolordava 2020). In its official statement regarding the attack, the Georgian Patriarchate blamed LGBTI activists for disrespecting historical memories and traditions. The politicians and the GOC, in other words, reconfirmed the idea of Orthodox Christianity and heterosexuality being parts of the concept of “Georgian nationhood,” a part of historical tradition. While the situation remained similar in 2021, the church now largely distances itself from the violence while blaming the protesters for bringing this on themselves.

In Ukraine, UCCRO’s media frequently discuss international institutions and organizations that threaten Ukrainian national security. One of them is the United Nations Fund for Population Activities (UNFPA), which pioneers the promotion of comprehensive sexuality education in Ukraine. Vseukrainski Sobor mentions several events organized by UNFPA that were somehow related to the protection of LGBTI rights, normalized homosexual relations, or spoke of the human rights of HIV-positive people. According to the authors, these events reveal the real ideological position of this organization, and women’s rights serve the UNFPA as a “Trojan horse” that will “bring inside the society [foreign] values and norms.”

Furthermore, joining international initiatives, such as the Istanbul Convention on violence against women and domestic violence,¹¹ or the Biarritz Partnership for Gender Equality, is seen as “creating a powerful mechanism to introduce gender ideology and punish those who oppose it.” The only way to resist is to insist that the government withdraw from international obligations that threaten Ukrainian families and the Ukrainian nation by disrupting traditional educational practices. The state, in other words, is expected to protect national security by ensuring that only certain kinds of sexualities and gender identities are recognized as “proper.”

Alternative Europeanization Frame

The geopolitical situation of Georgia and Ukraine has created for the national churches a particularly challenging position in their resistance to LGBTI rights as compared to the religious institutions in other Central and East European countries. For both countries, “political” orientation became tied to sexual orientation as the position toward LGBTI equality became tied to the pro-European or pro-Russian position. Due to the issues of territorial integrity and growing military aggression from the Russian side in Ukraine, the pro-European preferences of the general public became larger and could not be ignored. In Ukraine, the Ukrainian Orthodox Church gained its power mostly thanks to its pro-European and anti-Russian position, having supported the anti-governmental protests from the beginning of 2013. Not being accepted by the Moscow Patriarchate as a legitimate religious institution, the Ukrainian Orthodox Church needed to present itself as something that the Russian Orthodox Church was and is not.

The Georgian Orthodox Church is even more conflicted, as its older clergymen still revere the Moscow Patriarchate while seeing the West as the source of degraded spirituality. However, despite the close ties with Moscow and the Kremlin, the GOC has never questioned the European prospects of Georgia. Moreover, when on February 24, 2022, Russia launched its full-scale invasion of Ukraine, Patriarch Ilia II publicly condemned Russian Patriarch Kirill, who ignored the war in his speeches (RISU 2022). The Georgian government, in its turn, reconfirmed its intentions to join both the EU and NATO.

Nevertheless, the full support of the pro-Western or pro-European choice of foreign politics raises the inevitable question of values and acceptance of LGTI rights. A solution that the religious leaders in both countries are promoting now could be what I define as an “alternative” or “selective” Europeanization, that is, selective adoption of the norms and policies required by the EU. One of the previous sections already mentioned the conditions that Patriarch Ilia posed to European leaders. To gain the support of the GOC, the EU should respect traditional Georgian [Christian] values and culture.

Representatives of the GOC and UCCRO regularly hold meetings with diplomats from Western partner states and hold roundtables with their countries’ respective ministries of European integration. In these relations, when demonstrating open resistance against equality for LGBTI people, the clergymen often again appeal to human rights and freedoms as one of the European values. For example, in the official statement of the GOC against 2021’s Tbilisi Pride, it was stated that “our [Georgian] society has to understand that the European democracy is not a rejection of the way of thinking and living of the vast majority of people and their religious feelings” (GOC 2021). With this, the GOC appeals to the European Parliament’s and the member states’ representatives in Tbilisi, asking them not to support the march.

The recent backlash against gender equality and LGBTI rights in some of the EU member states gave even more room for discussion for national religious leaders. It became possible to appeal to the precedent of countries that, being EU members, could adopt national documents affecting the rights of women and LGBTI people, justifying those by conservative values and Christian tradition. Following the examples of Poland, Bulgaria, and Serbia, the UCCRO actively opposes ratification of the Istanbul Convention, an international document aimed at the prevention of gender-based violence mentioned above. The main reason for these objections is the words “gender” and “sexual orientation” mentioned in the document. The main objections voiced by the opponents of the Convention are related to the fact that while pretending to fight domestic violence (which is a worthy cause indeed, according to UCCRO), the Convention imposes on minors and young people wrong ideas about the concept of the family. The Istanbul Convention, the religious leaders claim, is the first document that contorts the definition of “gender” at the international level, making people believe that gender means something else rather than biological female and male sexes. Moreover, the Convention bans discrimination against people on the ground of their sexual orientation and gender identity, which, UCCRO’s representatives argue, will lead to the popularization of “new gender roles” and “same-sex relations” in Ukrainian schools, which will be “detrimental” for the Ukrainian nation. Since the Ukrainian Orthodox Church recognizes the importance of fighting domestic violence, they propose “to develop national legislation of Ukraine to counter domestic violence and violence against women, as other countries that refused to ratify this Convention have done (the UK, Lichtenstein, Latvia, Lithuania, Slovakia” (UCCRO 2020).

In other words, like the GOC, the Ukrainian religious groups have adopted new vocabulary during the last several years while preserving time-proven frames of morality and traditional family values. Furthermore, since the military conflict with Russia has caused growing nationalist moods in society, the Ukrainian Orthodox Church has used the momentum to gain more supporters. It had to learn to maneuver between its conservative position rejecting LGBTI equality and not being associated with promoting the values and ideas traditionally associated with Russia. In the meantime, the recent developments in neighboring EU member states, such as Poland and Hungary, where several steps against LGBTI rights and gender equality have been made, serve as a point of reference for Ukrainian (and Georgian) Church leaders who now claim their support for European values and European choices in foreign politics.

Conclusion

This article discussed the frames that the Georgian and Ukrainian Orthodox churches have used for resistance against gender and sexual equalities in their countries. In the twenty-first century, after their revival following the collapse of the Soviet Union, in both countries the national churches became the most publicly trusted institutions against political and economic instability and corruption, resulting in high public distrust toward the politicians. Correspondingly, seeing the church’s importance to the wider population, politicians in both countries could not ignore the clergy and had to demonstrate, at least formally, that their parties were on good terms with the national Orthodox Church.

Like many other religious institutions across Europe, the Georgian and Ukrainian Orthodox churches have always opposed the normalization of LGBTI rights in their countries and have been among the major actors resisting gender and sexual equalities. Nevertheless, their resistance, as compared to similar processes in other Central and East European countries, was complicated by both states’ geopolitical situations. Adoption or rejection of LGBTI rights in Georgia and Ukraine became a synonym for the foreign politics choice between the Europeanization (approximation with the European Union) and siding with Russia, which declared itself a regional protector of traditional family values.

In the period examined by this article (2014 to 2021), as the EU and civil society activists in Georgia and Ukraine put substantial efforts into promoting LGBTI rights in these countries, the Orthodox churches have played an important role in slowing down the progress and preventing adoption and implementation of LGBTI rights norms. In doing so, they were using common mobilization frames analyzed in this paper, namely, freedom of religion and human rights, protection of family and minors, and Orthodox Christianity as an integral part of “good” nationhood. As the previous sections show, these frames proved effective in stopping bills from adoption and led to the adoption of the documents harmful to the human rights of LGBTI people.

The recent decade has been marked by growing nationalist sentiment in both countries and worsening regional territorial disputes and military conflicts. Though a large part of the Ukrainian Orthodox Church–Moscow Patriarchate and the Georgian Orthodox Church preserved close ties with the Kremlin, the increasing popular support for European integration became impossible to ignore, and the churches have faced the necessity to adapt to a new geopolitical reality.

This article has spoken of the ways in which the Georgian and Ukrainian Orthodox churches are dealing with the need to accommodate the pro-European views of the public while staying loyal to their values. It argues that in their political activities, both national churches used four similar frames: the frame of freedom of religion and human rights; protection of minors (family) frame; religion and nationalism frame; and, finally, the frame of “alternative Europeanization.” As the article shows, these frames, or themes, deliberately chosen by the churches to mobilize their supporters, prove to be quite efficient in preventing progress with gender and sexual equalities in both countries.

The frames have also been changing with the times and with geopolitical developments in the region. Several years after the Euromaidan Revolution of 2013/14, arguments about the juxtaposition of “Russkii mir” (Russian world), with its traditional values, and “Gayropa,” the LGBTI-friendly European Union—are no longer much in evidence and are seen as anecdotal and simplistic even by those actors who widely used this argument just several years ago. Instead, the churches had to adjust their rhetoric placing a strong emphasis on the European choice in Georgian and Ukrainian foreign and domestic policies. While still referring to “traditional family values” and “protection of minors,” representatives of the church have also shifted toward more politically loaded terms such as “freedom of religion” and “national security.” Most interestingly, the national church leaders have proposed “alternative” or “selective” Europeanization, which would mean, in their understanding, the adoption of certain European norms in selected sectors while rejecting others, such as LGBTI rights. The Council of Churches in Ukraine is ready to provide their lawyers to adapt human rights norms that do not contradict religious values. The Georgian Orthodox Church representatives travel to discuss their country’s EU and NATO membership ambitions with local diplomats. The religious leaders warn the politicians “against direct extrapolation of European values on national terrain and unthoughtful harmonization between the national and European legislation” (NISS 2015).

Simultaneously, politicians in both countries also seem to be looking for a compromise between pro-Western rhetoric and a “Westernized” approach to policymaking and the need to consider the church as the most influential national institution. As the examples above show, this attempt to sit on two chairs results in formal declarations or even in the adoption of contradictory legal acts. For example, the bill on registered partnerships for same-sex couples mentioned in Ukraine’s National Human Rights Strategy never became a reality. After the law prohibiting discrimination against LGBTI people in Georgia was adopted, the amendment to the Constitution defining marriage as a union between a man and a woman soon followed. Such political behavior of the major parties in both countries is based not only on the realization of the recently increased importance of religious institutions, but also on a firm belief in the continuing predominance of conservative views among the population, which politicians imagine as homophobic and patriarchal. To support LGBTI people’s rights openly in both countries is still considered political suicide (Shevtsova 2020; Tolkachev and Tolordava 2020).

The findings of this article raise further questions about the role national religious institutions and religious leaders play in the country’s political life. In conditions where religious leaders have come to enjoy unprecedented public support and the general distrust toward the government, policymakers, and judicial system has grown, the challenges that advocates of LGBTI rights and gender and sexual equalities face are particularly strong. Therefore, it may be useful to explore how the efficient mobilization frames discussed in this article can be questioned and refuted, challenging the “selection” of the norms allowed to be Europeanized.

Acknowledgments

I want to thank David Paternotte and Ov Cristian Norocel for their support and suggestions to improve this work and their efforts invested into this special issue. I am also grateful to all the independent reviewers for their time and valuable comments.

Disclosure Statement

No potential conflict of interest was reported by the author(s).

Additional information

Funding

This project has received funding from the European Union's Horizon 2020 research and innovation programme under the Marie Skłodowska-Curie grant agreement n° 945380.

Notes

1. Throughout this article, the term LGBTI will be used to refer to Lesbian, Gay, Bisexual, Transgender, Intersex, or otherwise queer. This option is chosen to conform to the version used in the documents of the European Union and opts for the shorter acronym to represent the larger community of lesbian, gay, bisexual, transgender, intersex, asexual, pansexual, or otherwise queer/questioning individuals. When the acronym differs (for example, when I use “LGBT” instead) it is done because I am quoting or referring to a source that used this particular term.

2. The Eastern Partnership (EaP) is a joint policy initiative that aims to deepen and strengthen relations between the European Union (EU), its member states, and its six Eastern neighbors—Armenia, Azerbaijan, Belarus, Georgia, Moldova, and Ukraine.

3. The Moscow Patriarchate claimed to have 11,000 parishes in Ukraine in 2018, as compared to more than 4,200 parishes of the Ukrainian Orthodox Church–Kyiv Patriarchate and around 1,200 parishes of the Ukrainian Autocephalous Orthodox Church (Lilik et al. 2019).

4. See, for example, the World Value Survey, where Ukraine and Georgia are both placed in the category of countries where survival values prevail over self-expression ones, which, according to the authors, means that people in these countries “feel threatened by foreigners, ethnic diversity, and cultural change—which leads to intolerance of gays and other outgroups, insistence on traditional gender roles, and an authoritarian political outlook (World Value Survey 2020).

5. Ukraine’s second president, Leonid Kuchma, even published a book titled Ukraina ne Rossiya (Ukraine Is Not Russia). See also Kakabadze 2016; Luciani 2021.

6. ILGA is an international association of membership organizations that campaigns for lesbian, gay, bisexual, trans, and intersex rights. See ILGA Europe’s official web-page, https://www.ilga-europe.org/rainboweurope/2021. Accessed on August 23, 2021.

7. For example, in 2015, Volodymyr Groisman, the speaker of Verkhovna Rada, made a statement that there would be no same-sex marriages in Ukraine despite having adopted the National Human Rights Strategy, which included a plan to develop a bill on registered partnerships for same-sex couples in Ukraine. The bill has never been registered.

8. It is important to point out that neither Ukrainian Orthodox Church nor the Georgian Orthodox Church is the only church in those countries. In Georgia, major religious minorities include Muslim (approximately 10 percent), Armenian Apostolic (around 4 percent), and Catholic (some 0.5 percent) populations. In Ukraine, 9.4 percent of the population define themselves as Ukrainian Byzantine Rite Catholics, 2.2 percent as Protestants, followed by 0.8 percent Latin Rite Catholics. Judaism is religion of some 0.4 percent of the population of the country. For the sake of brevity, I do not discuss the participation of some of these groups in anti-gender campaigns, although some aspects of it, for example, the support coming from US Protestant groups, should be addressed in further works on the issue.

9. The May 17 date was chosen by IDAHOT’s founders to commemorate the decision to remove homosexuality from the World Health Organization’s International Classification of Diseases in 1990.

10. Comprehensive Sexuality Education is a “rights-based and gender-focused approach to sexuality education, whether in school or out of school” that is expected to include “scientifically accurate information about human development, anatomy, and reproductive health, as well as information about contraception, childbirth, and sexually transmitted infections (STIs), including HIV” (UN Population Fund 2021). In both states it met strong opposition from the side of conservative groups, including the Orthodox churches.

11. The Council of Europe Convention on preventing and combating violence against women and domestic violence, known as the Istanbul Convention, is a human rights treaty of the Council of Europe against violence against women and domestic violence. The document was opened for signature on May 11, 2011, in Istanbul, Turkey. The goal of the Convention is to prevent gender-based violence, protect victims, and end the impunity of perpetrators. It is mentioned here since in many Central and East European countries this Convention has met resistance from anti-LGBTI groups which have claimed that mention in the document of sexual orientation and gender identity can somehow lead to the imposition of same-sex marriages or “gender ideology” on their countries. This is the case of Ukraine while in Georgia, where the situation with gender-based violence has large resonance, its ratification was mostly welcomed by human rights activists and passed without notice from the Georgian Orthodox Church.