Problematic situations of the use of firearms by security and escort police units in relation to exceptional categories of citizens.

Chepik Irina Viktorovna Senior lecturer; Department of Organization of Security and Convoy Police units; Tyumen Institute for Advanced Training of Employees of the Ministry of Internal Affairs of the Russian Federation 75 Amurskaya str., Tyumen, Tyumen region, 625049, Russia barkovairinav@mail.ru Other publications by this author

Introduction.

Police activity in general is associated with risk and a high probability of emergency situations, for which a police officer must be prepared, not only theoretically and practically, but also psychologically. Not every person, in principle, will dare to use firearms, especially against another person, and even more so if this person is a woman, a child or has any physical limitations, that is, does not carry a potential danger externally and may actually be weaker than a police officer with special training.

The relevance of this topic is emphasized by the fact that in the activities of employees of security and convoy units of the police, situations of an emergency nature may arise, requiring urgent measures to prevent irreversible consequences, including the use of firearms. Emergency situations may be associated, for example, with an attack on police officers and other citizens, hostage-taking, escape of suspects, accused persons from custody and, accordingly, violation of the detention regime established for such persons, internal regulations, isolation both internal and external, which may contribute to the onset of even more significant and devastating consequences both for the police and for the whole society ^{[1, pp.10, 11]}. It is extremely important to constantly simulate such situations during the passage of professional training by police officers, as well as classes and trainings within the framework of combat and service training, so that in practice they spend less time realizing the fact and analyzing the situation than making an informed decision and carrying out the necessary set of actions. Possible situations of the use of firearms, as well as relevant restrictions and prohibitions are presented in the Federal Law "On Police", however, conditions may actually arise that require a police officer to know additional legal norms, systematize them and draw consistent conclusions, in this regard, the study analyzes atypical situations of possible use of firearms in the activities of the security and escort units of the police. In particular, exceptional categories of citizens (women, persons with obvious signs of disability, minors) may have a certain procedural status, be suspects, accused of committing crimes, detained, in connection with this, convicted, persons against whom a preventive measure in the form of detention has been chosen, and may also not have such a status to possess, but to be relatives or other close persons in custody. That is, exceptional categories of citizens can commit both an internal (when they are escorted by a squad of a security and convoy police unit) and an external attack (on persons in custody, a convoy), attempt to escape personally or be an accomplice in the escape by another person under guard, take measures to illegally release from custody.

In this regard, if there are grounds, the officers of the police convoy will face a difficult task about the possibility of using firearms against such persons carrying out illegal actions. On the one hand, the composition of the outfit has certain knowledge about the persons who come to its disposal (their identification data, health status, age, danger of the committed act), on the other hand, it may not know and evaluate in a short time any features of persons who are not under the protection of the convoy and commit against it or illegal actions of the special agent protected by him.

The Federal Law "On Police" contains a ban on the use of firearms against exceptional categories of citizens by the police (such protection is primarily due to the characteristics available in general to these persons, who are weaker, have limited capabilities in relation to adult men), but is not absolute due to the fact that they may be Illegal actions have also been taken that threaten the life and health of a police officer or other citizens.

The scientific novelty of the conducted research lies in the fact that from the standpoint of legal norms, situations of possible use of firearms in relation to exceptional categories of citizens are considered, which, regarding the activities of security and convoy units of the police, have not been previously analyzed. It is proposed to simulate these situations in training sessions with security and convoy units of the police. Fundamentally new is the study of the issue of changing the sex of a suspect (accused) from male to female and the possibility of using firearms against such a person in the context of the norms of the Federal Law "On Police".

The purpose is to consider situations of possible use of firearms in relation to exceptional categories of citizens

Tasks:

1. To understand the purpose of the security and escort units of the police;

2. To consider the legal regulation of the use of firearms in the activities of security and convoy units of the police;

3. Identify the exceptional categories of citizens in respect of whom the Federal Law "On Police" prohibits the use of firearms;

4. To analyze the problematic situations of the use of firearms in the activities of security and convoy police units described in the article.

5. To propose ways to effectively solve the problem situations under consideration.

The research methodology is represented by general scientific (analysis, synthesis, generalization, induction, deduction) and private scientific methods (comparative legal method, modeling).

The main part

Security and convoy police units are a structural subdivision of the territorial body of the Ministry of Internal Affairs of Russia at the interregional, regional, and district levels, exercising the powers of the internal affairs bodies of the Russian Federation to protect and escort detained and detained persons^[1] and can be formed as separate units (temporary detention facility^[2], regiment, separate battalion, a separate company, a separate platoon, etc.) or composite (a company as part of a separate battalion, a platoon (squad, group) of protection and escort of suspects and accused IVS, etc.)^[3]. The tasks and functions of the police units in question are named in the relevant regulatory legal framework governing the activities of these units^[4] and are reduced to the detention, protection and escort of suspects, accused at the request of the court, the investigator, the body of inquiry and other authorized persons from places of detention^[5] to the court, IVS, pre-trial detention center, the place of investigative actions, medical organizations, etc . and the prevention of emergencies at the same time.

The use of firearms in the activities of security and convoy police units is an extreme situation and is somewhat less common than in other police units, since persons who are already in custody (in the physical sense of the word - under guard – detained in accordance with the procedure 91, 92 of the Criminal Procedure Code of the Russian Federation; persons are placed in the IVS and, accordingly, escorted who have chosen a preventive measure in the form of detention; convicted persons) and immediately, upon taking them into custody, become familiar with the internal regulations^[6], which they are obliged to comply with, as well as the requirements ensuring the regime of detention^{[7] [2, pp. 52-55]}, if they are not fulfilled in relation to Appropriate coercive measures may be applied to them. In addition, through a complex of interrelated actions, employees of security and convoy units, among others, perform tasks to prevent emergency situations, which can generally be calculated and predicted on the basis of available generalized data from judicial practice, reviews, regulatory legal acts, methodological recommendations, scientific support, etc.

The legal regulation of the use of firearms in the activities of security and convoy police units is mainly reduced to the norms of the Federal Law "On Police", which contain both constitutional principles and indirect norms of international law^[8], as well as a reference to the relevant articles of the Criminal Code of the Russian Federation^[9]. Certain norms of legal regulation contain federal constitutional laws^[10], which generally do not affect the procedure for the use of firearms in ordinary, peacetime, the Federal Law "On Service in the Department of Internal Affairs"^[11] gives the police the right to use firearms in general. Some legal norms will restrain prohibitions that apply not only to police officers, but also to the entire procedure for the turnover of firearms, therefore they can also be considered a legal regulator in this area^[12]. For example, a ban on carrying firearms while intoxicated.

Previously, along with the Federal Law "Police", the legal regulation of the use of firearms in the activities of security and convoy units of the police was contained in Article 47 of Federal Law No. 103 - FZ dated 07/15/1995 "On the detention of suspects and accused of committing crimes", which became invalid in 2016. Currently, Article 43 of the said federal law refers to the Federal Law "On Police" in order to clarify the cases and procedure for the use of firearms in places of detention held by the police department.

The Federal Law "On Police" is an official collection of algorithms of actions that police officers must adhere to before, during and after the use of firearms. In addition, Article 23 of the said federal law also contains prohibitions on the use of firearms "with the production of a shot to kill" in relation to legislatively established exceptional categories of citizens, which include women (gender), persons with pronounced disabilities (visible physical or mental abnormalities) and persons known to be minors for police officers (under the age of 18). However, the ban on the use of firearms against these citizens is not unconditional. When "these persons provide armed resistance, commit an armed or group attack that threatens the life and health of citizens or a police officer"^[13] these prohibitions cease to apply.

Part 2 of Article 23 of the Federal Law "On Police" contains a definition of armed resistance and armed attack, which must be carried out using weapons of any kind or other objects similar to real weapons in design and appearance, as well as "objects, substances and mechanisms with which serious harm to health or death can be caused"^[14]. Thus, if a citizen, against whom it is prohibited to use firearms, resists or attacks armed with any of the listed items or weapons, these prohibitions cease to apply to him. Another exception to the prohibitions on the use of firearms is the commission of a "group attack that threatens the life and health of citizens or a police officer"^[15]. "The very nature of the threat is not specified, which makes it possible to imagine the possibility of a threat of causing any harm, up to beatings" ^{[3, p.125]}.

A group attack can be carried out by two or more persons, respectively, a single attack cannot be considered an exception to the prohibitions on the use of firearms by police officers. That is, in fact, the Federal Law "On Police" deprives a police officer of the right to protection from a single attack with a firearm. A.I. Kaplunov in a monographic study draws attention to the imperfection of prohibitions in the use of firearms provided for by the Federal Law "On Police" and insists on the legislative rejection of these prohibitions ^{[4, p. 137]}.

O.Y. Filippov and A.V. S. enognoev, conducting a comparative legal analysis of the grounds for the use of firearms by police officers and employees (military personnel) of the Rosgvardiya, draw attention to the fact that much more powers have been established for the National Guard troops, and "the applied wording^[16] "other attack" allows considering any attack, including including the individual" ^{[3, p. 125]}, which is not available in the Federal Law "On Police".

During training sessions in security and escort units of the police, situations related to the implementation of a single unarmed attack (strangulation option) on an injured police officer by a woman, a disabled person or a minor in conditions of violation of the order of protection and escort (for example, escorting in court is carried out by one employee), another emergency (fire, flood, traffic accident), when other police officers are unconscious (injured, dead) or absent. The only means of escape in such circumstances for a police officer could be the use of firearms.

In our opinion, in accordance with Part 3 of Article 19 of the Federal Law "On Police", a police officer in the situation described above "acts taking into account the prevailing situation, the nature and degree of danger of persons' actions ..." on the basis of the norms of Article 37 of the Criminal Code of the Russian Federation on necessary defense, which apply to all persons. The team of authors led by I.V. Lesovik draws attention to the fact that "criminal law norms do not cancel or contradict the requirements of the Federal Law "On Police" in terms of the requirements to act taking into account the prevailing situation, the nature and degree of danger of a person's actions and the strength of the resistance they provide" ^{[5, p. 19]}.In addition, Part 3 of Article 18 of the Federal Law "On Police" extends the right of a police officer to protection in the event of circumstances precluding the criminality of an act, in particular, allowing the use of any improvised means, as well as weapons not in service with the police. Therefore, the use of weapons armed with the police in such conditions will, on the contrary, be more justified. I.E. Terenkov, considering a similar situation from a slightly different projection, indicates that this permission "works" exclusively in the absence of the necessary special means and firearms from a police officer and, in defense of his position, summarizes that in some situations it is improvised means can save the life of a police officer or citizens. ^{[6, C. 204]}. We agree with this statement, but at the same time we assume that this norm does not require such a literal interpretation of the lack of special means and firearms, firstly, firearms may be with a police officer, but for specific reasons he cannot use them (lack of necessary ammunition, damage to weapons, delays in shooting secondly, the use of improvised means in some cases may be more likely to ensure the minimization of damage required by law and eliminate delay in application (for example, the use of dust in /near the hand of a police officer thrown into the eyes of an attacker to disorient him instead of using tear gas, which may be in a specific situation in in a less accessible place, in addition, it will have some effect on the senses of a police officer and will have a longer impact). In general, the scientist supports the above-mentioned position of using the norms on necessary defense and the Federal Law "On Police".

However, there is also an opposite point of view of A.Y. Bordachev, who connects the right to use firearms by police officers only in accordance with the Federal Law "On Police" ^{[7, p.169]}. V.A. Burchikauskas notes that a police officer can be and himself be a woman ^{[8, P.45]}, which can significantly reduce the possibility of countering an attacker.

In our opinion, taking into account the provisions of Article 19 of the Federal Law "On Police", we should also talk about banning the use of firearms against a minor, if there are grounds for that, for example, when he commits a single attack on an employee of a security and escort police unit, threatening his life and health. In the explanation of the Plenum of the Supreme Court of the Russian Federation^[17] on the necessary defense, attention is drawn to the fact that it can be recognized as legitimate even if the encroaching person does not reach the age from which criminal liability begins, that is, in accordance with Article 20 of the Criminal Code of the Russian Federation – 14 or 16 years.

The fact that the above situations can occur in the official activities of employees of security and convoy units of the police is also evidenced by judicial practice.

Thus, the defendant, acting intentionally, forcefully struck the escort with the handle of one of the crutches with which he moved, since his right leg was amputated above the knee, in the face area, that is, he used violence dangerous to his health^[18].

Having the intention to use violence that is not dangerous to life and health, acting intentionally, she used violence against a police officer in the performance of her official duties, pushing her with her hands into the chest area, then hitting her with her elbow in the area of the left cheekbone, from which the latter hit the occipital part of the head against the metal door of the car^[19].

Illegally, intentionally, realizing the illegality of his actions, he struck the victim at least three times with an orthopedic walking stick in the area of her right arm and back, which caused her physical pain^[20].

Excerpts from the above sentences indicate that exceptional categories, in respect of which the use of firearms to kill is prohibited, may actually not be so defenseless. Nevertheless, in the examples given, there are no grounds for the use of firearms, since, in order to minimize damage, other coercive measures and restoration of law and order could have been used, in addition, it was possible to get help from other police officers.

In the realities of the present time, it would not be superfluous to consider such a phenomenon when the suspect, the accused is a woman who is not quite a woman in the truest sense of the word. For example, according to Article 19 of the Law of the Republic of Belarus "On Healthcare", the change and correction of gender identity are carried out at the request of an adult patient ^{[9, C.49]}. Russian legislation prohibits sex reassignment^[21], but other medical interventions are allowed, the result of which may be a sex reassignment, which entails making changes to the civil status record. However, this does not mean that there are no such persons in our country or there are few of them, such citizens may come from other countries or change their gender earlier, according to a more simplified scheme. O.G. Zubareva in her research draws attention to the fact that it is easy to obtain a certificate of sex change from the end of 2017. even citizens who did not undergo hormone therapy and surgical sex correction ^{[10, p.81]}, which entailed legal consequences - "entering information about gender in the record of the birth certificate of a citizen, subsequent name change in the registry office, and then replacing the identity document (passport) in the migration authorities ATS" ^{[10, p.81]}. How should such a person be regarded in the context of the application of the norms of the Federal Law "On Police", in particular on the use of firearms?

The gender of a citizen is identified on the basis of an identity document, the main such document in the Russian Federation is a passport of a citizen of the Russian Federation (or another document)^[22], according to which the suspect, the accused is assigned to a place of detention.

It is indisputable that a man who became a woman only according to documents, who did not undergo hormone therapy and surgery in fact - the same man remained in terms of physical superiority and other characteristics, at the same time, who underwent surgery can, without taking hormone therapy, for example, in a place of detention, preserve male data.

Are there prohibitions on the use of firearms against such a category of citizens if there are appropriate grounds, for example, when escaping from the convoy of a person detained on suspicion of committing a crime (when attacking a female escort)?

In accordance with Article 19 of the Federal Law "On Police", a police officer acts "taking into account the prevailing situation, the nature and degree of danger of the actions of persons against whom physical force, special means or firearms are used, the nature and strength of their resistance"^[23], is it possible in such a case, "an exception from the exception"? We believe that yes, but it is worth paying attention to the fact that this phenomenon has not yet been sufficiently studied due to the lack of precedents and relevant judicial practice. Nevertheless, this issue is quite relevant, especially in large or border towns and is currently outside the legal framework. In the practical activities of the security and escort unit of the police, in which the author previously served, there was a practice of escorting such a person. The woman (according to the documents) did not have time to give her body a proper appearance before her arrest and had both primary male and secondary female sexual characteristics.

When conducting training sessions in security and convoy police units, modeling such situations will be especially interesting, new, informative, and will require a comprehensive analysis of the very introductory and legal grounds for the use of firearms.

It is worth noting that having legal grounds for the use of firearms, not every police officer will be able to use it, this may be due to the lack of determination of the officer himself, his uncertainty that the actions will be given a proper objective assessment, the low level of professional training of police officers, imperfection of legislation in this area ^{[11, C. 309]}.

Conclusion.

The situations we have considered of the possible use of firearms in the activities of security and convoy police units, if there are appropriate grounds for this, can be used when conducting classes with police officers of the appropriate training profile for group discussion within the framework of the problem-based training method, as well as with employees of other police units, since they may also meet in other conditions of official activity.

In the classroom, introductory situations can be modeled - supplemented, expanded, endowing with various characteristics of the offender. For example, a clear sign of disability will also be a visible difference in the length of the accused's arms, which absolutely may not prevent him from running well.

Conclusions:

The main purpose of the security and escort units of the police is the protection, escort and detention of suspects accused of committing crimes in conditions that ensure their isolation, as well as the prevention of emergencies.

Firearms may be used with the guards of the security and convoy units of the police in case of emergency situations in accordance with the Federal Law "On Police" and the Criminal Code of the Russian Federation.

The ban on the use of firearms is not absolute.

Exceptional categories of citizens include: women, minors known to a police officer, and persons with obvious signs of disability.

In each specific situation of the possible use of firearms against exceptional categories of citizens, an employee of the security and convoy police unit is obliged to strive to minimize damage, while being guided by the norms of the Federal Law "On Police" and the Criminal Code of the Russian Federation.

The study examines two problematic situations of the use of firearms by employees of security and convoy units of the police:

1. The possibility of using firearms against exceptional categories of citizens, when they provide an unarmed single attack on a police officer who is in a state of necessary defense, is generally supported in the works of other authors. Such an attack is not excluded in the activities of security and escort units of the police and can be committed, for example, during another emergency, in violation of the security order.

2. The possibility of using firearms in order to prevent escape (paragraph 7 of Part 1 of Article 23 of the Federal Law "On Police"), committed by a woman who actually has male data, has not been investigated by other authors, in our opinion, the convoy officer acts taking into account Part 3 of Article 19 "On Police" and the characterizing material in relation to this persons (article(s) of the charge, previous convictions, public danger of the acts and the person himself, propensity to illegal actions, etc.). This phenomenon can occur in the practical activities of convoy employees, requires further research within the framework of the likely use of firearms against such a person in order to exclude the occurrence of more serious consequences (escape of a particularly dangerous person a criminal from custody, after which the fugitive may commit robbery, rape, murder and other crimes).

Ways to effectively solve such problematic situations at the legislative level have not yet been proposed. The above suggests that if the situations described in the article arise in practice, an employee of the security and convoy police unit will either refuse to use firearms, or, having used it, will have difficulty specifying the legal grounds for his actions.

In this regard, we propose to make the following changes to the Federal Law "On Police":

To state Part 5 of Article 23 in the following wording: "It is prohibited to use firearms with the production of a shot to kill against women with visible signs of pregnancy, persons with obvious signs of disability, minors when their age is obvious or known to a police officer, except in cases of armed resistance by these persons, group or other attacks threatening the life and health of citizens or a police officer."

The introduction of these changes will not entail the occurrence in practice of the problematic situations discussed in the article, since they will be eliminated due to the new formulations.

The first change "With visible signs of pregnancy" will allow to narrow the range of prohibitions, to single out from all female persons only women with a special status - the presence of pregnancy, in this case there will be no dilemma about determining the actual sex of a citizen. In particular, it is precisely this wording that currently determines the prohibition on the use of firearms in the Law of the Russian Federation No. 5473-I of July 21, 1993 "On Institutions and Bodies of the Penal Enforcement system of the Russian Federation", which protect and escort, for example, those detained in a pre-trial detention center, the same suspects, accused, convicted, who are being escorted by the police.

The second change will allow, when committing a "different" attack on a police officer or citizens, to use firearms when repelling a single non-armed attack that threatens their life and health, if it is impossible and ineffective to use other means of protection.

^[1] Order of the Ministry of Internal Affairs No. 1266 of the Russian Federation dated 12/31/2015 "On improving the organization of temporary detention facilities for suspects and accused of internal affairs bodies, security and escort units for suspects and accused, special receivers for the detention of persons subjected to administrative arrest" [Electronic resource] // Access from the specialized geographically distributed automated system STRAS "LAWYER".

^[2] Further – "IVS".

^[3] Order of the Ministry of Internal Affairs of Russia dated July 17, 2023 No. 517 "On approval of the List of positions in temporary detention facilities for Suspects and Accused, security and escort units for suspects and accused, the performance of duties for which grants the right to preferential calculation of length of service for the appointment of pensions, and determining the conditions for granting the right to preferential calculation of length of service for pension appointments" [Electronic resource] // Access from the ConsultantPlus legal reference system.

^[4] Federal Law No. 3-FZ dated 7.02.2011 "On the Police" [Electronic resource] // Access from the ConsultantPlus legal reference system; Order of the Ministry of Internal Affairs No. 1266 of the Russian Federation dated 12/31/2015 "On improving the organization of the activities of temporary detention facilities for suspects and accused of internal affairs bodies, security and escort units for suspects and accused, special receivers for the detention of persons subjected to administrative arrest" [Electronic resource] // Access from the specialized geographically distributed automated system STRAS "LAWYER"; Order of the Ministry of Internal Affairs of Russia dated November 22, 2005 No. 950 "On approval of the Internal Regulations of temporary detention facilities for suspects and accused of internal affairs bodies" [Electronic resource] // Access from the ConsultantPlus legal reference system, as well as departmental NPAs intended for official use.

^[5] In accordance with Article 7 of the Federal Law of the Russian Federation dated 07/15/1995 No. 103-FZ "On the detention of suspects and accused of committing crimes" [Electronic resource] // Access from the ConsultantPlus legal reference system - these can be the IVS of the Department of Internal Affairs, the SIZO (Pre-trial detention center of the penal enforcement system), etc.

^[6] Federal Law of the Russian Federation No. 103-FZ dated 07/15/1995 "On the detention of suspects and accused of committing crimes" [Electronic resource] // Access from the ConsultantPlus legal reference system, Order of the Ministry of Internal Affairs of the Russian Federation No. 950 dated November 22, 2005 "On Approval of the Internal Regulations of Temporary Detention Facilities for Suspects and Accused of Internal Affairs bodies" [Electronic resource] // Access from the ConsultantPlus legal reference system, as well as departmental NPAs intended for official use.

^[7] Articles 15, 16 of the Federal Law of the Russian Federation dated 07/15/1995 No. 103-FZ "On the detention of suspects and accused of committing crimes" [Electronic resource] // Access from the ConsultantPlus legal reference system.

^[8] For example, Rules 38, 82 of the Standard Minimum Rules for the Treatment of Prisoners (Nelson Mandela Rules) (revised text) (adopted by UN General Assembly Resolution 17.12.2015) // ATP https://constitution .garant.ru.

^[9] Articles 37, 38, 39 of the Criminal Code of the Russian Federation dated 06/13/1996 No. 63-FZ [Electronic resource] // Access from the ConsultantPlus legal reference system.

^[10] Article 30, Article 34 of the Federal Constitutional Law of the Russian Federation dated 30.05.2001 No. 3-FKZ (as amended on 11/22/2023) "On the state of emergency" [Electronic resource] // Access from the ConsultantPlus legal reference system (Accessed 05/04/2024). Article 20 of the Federal Constitutional Law No. 1-FKZ dated 30.01.2002 (as amended on 11/22/2023) "On Martial Law" [Electronic resource] // Access from the ConsultantPlus legal reference system.

^[11] Federal Law No. 342-FZ of 11/30/2011 (as amended on 02/26/2024) "On Service in the Internal Affairs Bodies of the Russian Federation and Amendments to Certain Legislative Acts of the Russian Federation" (with amendments and Additions, intro. effective from 03/12/2024) [Electronic resource] // Access from the ConsultantPlus legal reference system.

^[12] Part 5 of Article 6 of the Federal Law "On Weapons" dated December 13, 1996 No. 150-FZ [Electronic resource] // Access from the ConsultantPlus legal reference system.

^[13] Part 5 of Article 23 of Federal Law No. 3-FZ dated 02/7/2011 "On Police" [Electronic resource] // Access from the ConsultantPlus legal reference system.

^[14] Part 2 of Article 23 of the Federal Law No. 3-FZ dated 7.02.2011 "On Police" [Electronic resource] // Access from the ConsultantPlus legal reference system.

^[15] Part 5 of Article 23 of Federal Law No. 3-FZ dated 02/7/2011 "On Police" [Electronic resource] // Access from the ConsultantPlus legal reference system.

^[16] In Article 21 of Federal Law No. 226-FZ dated 07/03/2016 "On the Troops of the National Guard of the Russian Federation" - author's note.

^[17] Paragraph 5 of the Resolution of the Plenum of the Supreme Court of the Russian Federation dated 09/27/2012 No. 19 (ed. dated 05/31/2022) "On the application by courts of legislation on necessary defense and causing harm when detaining a person who committed a crime" [Electronic resource] // Access from the ConsultantPlus legal reference system.

^[18] Sentence No. 1-473/2015 1-52/2016 dated April 7, 2016 Pskov City Court (Pskov region) // Judicial and regulatory acts of the Russian Federation [Electronic resource].

^[19] Sentence No. 1-1005/2019 1-97/2020 Prikubansky district Court of Krasnodar (Krasnodar Territory) // Judicial and regulatory acts of the Russian Federation [Electronic resource].

^[20] Verdict No. 1-27/2020 of April 24, 2020 of the Velsky District Court (Arkhangelsk region) // Judicial and regulatory acts of the Russian Federation [Electronic resource].

^[21] Article 45.1 "Prohibition of sex change" of Federal Law No. 323-FZ dated November 21, 2011 "On the basics of public health protection in the Russian Federation" [Electronic resource] // Access from the ConsultantPlus legal reference system.

^[22] Decree of the President of the Russian Federation dated 11/22/2023 No. 889 (as amended dated 04.01.2024) "Issues of citizenship of the Russian Federation" // Access from the ConsultantPlus legal reference system.

^[23] Part 3 of Article 19 of Federal Law No. 3-FZ dated 07.02.2011 "On Police" [Electronic resource] // Access from the ConsultantPlus legal reference system.