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annul the regulation of the European Parliament and the Commission of the European Union of 20 June 2019 (2018/0104/COD, Lex 1939/PE-CONS 70/19) on strengthening the security of identity cards of Union citizens and of residence documents issued to Union citizens and their family members exercising their right of free movement; (1)

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order the defendants to pay the costs.

1.

First plea, alleging that the contested regulation adversely affects human dignity, private life and personal freedom, as well as the right to protection of personal data and to express consent for any processing of such data.

2.

Second plea, alleging that the contested regulation adversely affects the applicants’ religious conscience, in breach, inter alia, of Article 10(1) of the Charter of Fundamental Rights of the European Union.

3.

Third plea, alleging that, by making electronic identity mandatory without citizens’ prior consent, the contested regulation infringes the applicants’ right to object on the particular aforementioned grounds of religious conscience, in breach of Article 10(2) of the Charter of Fundamental Rights of the European Union.

4.

Fourth plea, alleging that, by adversely affecting the applicants’ religious conscience, the contested regulation at the same time also adversely affects their human dignity since religious conscience is a fundamental expression thereof, in breach of Article 1 of the Charter of Fundamental Rights of the European Union.