Legal prism — 2026-10-26

Article 569(1) of the Code of Administrative Offences classifies video recordings as evidence and provides that the evidentiary value of electronic data is the same as that of other evidence.

Article 2.23(1) of the Civil Code provides that information about a person's private life may be disclosed only with their consent, and Article 2.24 of the Civil Code grants the right to demand a denial of the disseminated data and compensation for damage.

Core issue

After a traffic incident, the legal position of the owner of a dashcam recording is determined not by the recording itself, but by to whom and how the material is subsequently used: when handed over to an insurer or the police, it operates as evidence, whereas when published on social media it may become the basis of an independent matter of liability. The precise legal question arising from this situation is twofold: first, what evidentiary value a dashcam video acquires in administrative offence, civil, or criminal proceedings; second, whether publication of the recording violates the right to private life of the persons captured in it. The first question is resolved under Article 569 of the Code of Administrative Offences; in civil cases, Article 220 of the Code of Civil Procedure applies, and in criminal cases, Article 276 of the Code of Criminal Procedure. The second question is resolved under Article 2.23 of the Civil Code and Regulation (EU) 2016/679 (the General Data Protection Regulation).

Legal assessment

The significance of the recording in the evidentiary process is established as follows:

• Article 569(1) of the Code of Administrative Offences classifies video recordings as evidence by which officials establish the fact of the offence, guilt, and circumstances mitigating or aggravating liability; the evidentiary value of electronic data is equal to that of other evidence.
• Article 593(1)(7) of the Code of Administrative Offences gives the investigating officials the right to demand objects and documents relevant to the case, and Article 594 provides that filming and video recording may take place during investigative actions and must be recorded in the protocol.
• Article 220(1) of the Code of Civil Procedure governs the examination at a court hearing of video recordings submitted to the court as evidence; Article 198 establishes the procedure for submitting written evidence and evidence related thereto, and Article 209 — the inspection of physical evidence.
• Article 276 of the Code of Criminal Procedure permits, at a trial hearing, the replaying and viewing of previously made audio and video recordings where a witness does not remember the circumstances, evades giving testimony, or where the testimony differs substantially.
• Article 109 of the Code of Criminal Procedure allows the victim to bring a civil claim in criminal proceedings, and during the pre-trial investigation data must be collected confirming the basis and amount of the claim — the recording may here serve as a source substantiating the circumstances of the damage. The assessment of publication is different. Article 2.23(1) of the Civil Code provides that private life is inviolable and that information about a person's private life may be disclosed only with their consent; Article 2.23(3) of the Civil Code prohibits the dissemination of collected information about private life, except where dissemination corresponds to a legitimate and justified public interest. Recital 18 of the GDPR expressly excludes the application of the Regulation to purely personal or household activities, but this exemption no longer applies where the recording is published on social media to a wide audience — such dissemination, under Article 4(2) of the GDPR, is in itself the processing of data. Recital 47 of the GDPR permits the processing of data on the basis of a legitimate interest, for example, handing it over to an insurer or the police for the investigation of the incident, provided the interests of the data subject do not override it. Where Article 2.23 of the Civil Code is violated, the person captured in the recording has the right to apply to the competent authorities or the court, and Article 2.24(1) of the Civil Code grants the right to demand a denial of the disseminated data and compensation for pecuniary and non-pecuniary damage; it is presumed that the disseminated data does not correspond to reality until the person who disseminated it proves otherwise.

Consequences

In practice, a driver holding a dashcam recording faces two distinct paths:

• If the recording is needed for the investigation of the incident — it must be locked or separately saved in good time and a copy made; the original, unedited recording should be handed over to the insurer or the police, since trimming complicates the assessment of what occurred beyond the fragment.
• If the recording is published on social media — there is a risk that the persons captured, having nothing to do with the dispute, will demand a denial and compensation under Articles 2.23 and 2.24 of the Civil Code, and data protection issues may be resolved under the GDPR. For insurers and the police this matters because of the quality of the evidentiary base: Article 569 of the Code of Administrative Offences and Article 220 of the Code of Civil Procedure confirm that the recording is assessed together with explanations, photographs, and damage, and not in isolation. For persons who believe that their rights have been violated by a published recording, the sources indicate the possibility of applying to the competent authorities or the court.

Under Article 8-2(1) of the Road Transport Code, it is prohibited to conduct paid passenger transport activities using passenger cars without a valid permit or while the permit is suspended.

In 2025, 500 ride-sharing permits were suspended and 300 revoked, and insurance for ride-sharing drivers costs EUR 300–600, compared with approximately EUR 90 for an ordinary driver.

Core issue

Persons operating as ride-sharing drivers without a valid ride-sharing permit or with a suspended permit may not lawfully conduct paid passenger transport activities in Lithuania — this is prohibited by Article 8-2(1) of the Road Transport Code of the Republic of Lithuania, and the suspension or revocation of a permit is a real consequence awaiting participants in this market, which in 2025 practice has already been applied in 500 suspended and 300 revoked permit cases. The precise legal question is under what conditions the LTSA may suspend or revoke a ride-sharing permit where the driver submitted a more expensive insurance policy to obtain the permit and subsequently replaced it with a cheaper one, uses an invalid technical inspection, or where other persons use a permit linked to another individual; this question will be resolved under the provisions of Article 8-2 of the Road Transport Code on the suspension and revocation of permits, and Article 13, which assigns state road transport supervision to the Transport Safety Administration, municipal services, and other state institutions, including the police. Additionally applicable is Article 29 of the Law on Road Traffic Safety, under which owners of motor vehicles registered in Lithuania must submit them for mandatory technical inspection.

Legal assessment

Under Article 8-2(2) of the Road Transport Code, a permit holder must meet the established requirements not only when obtaining the permit but also while holding it — this means that non-compliance with insurance, technical inspection, or identity requirements at any point during the activity may constitute grounds for revoking the permit, not merely for refusing to issue it. The LTSA, as the supervisory authority designated in Article 13, has the right to require the carrier to provide data on passenger transport contracts concluded on demand and other documents necessary for supervisory purposes (Article 18-1(3)), and the passenger transport organiser must, before the trip, provide the passenger with the driver's first name, surname, ride-sharing permit number, vehicle registration plate number, and trip price, and after the trip — no later than within one hour — generate a trip and payment document (Article 18-1(4)–(5)); it is precisely this data that would enable the LTSA to determine whether the account is being used by the same person to whom the permit was issued. In the area of technical inspections, Article 29(1) of the Road Traffic Safety Law obliges owners to submit vehicles for mandatory inspection, the purpose of which, under Article 2(56), is to ensure that vehicles comply with road safety and environmental requirements; an inspection performed in another EU Member State is recognised if still valid, and in cases of doubt the national contact point liaises with the authority of the state that performed it. A similar verification mechanism operates in the area of driving licences: according to a representative of "Regitra," citizens of third countries exchanging their licence for a Lithuanian one must take both theory and practical examinations, whereas a licence issued in an EU Member State need not be exchanged — as illustrated by the LTSA head, through cooperation with foreign authorities cases have already been identified in which third-country nationals used licences that had never been issued at all, and in such cases the permits were revoked. The sources contain no case law, and therefore I cannot cite any precedent.

Consequences

Practical consequences for ride-sharing drivers who replace their insurance policy with a cheaper one, drive with an invalid technical inspection, or allow others to use their account:

• The LTSA may suspend or revoke the ride-sharing permit under Article 8-2 of the Road Transport Code.
• Conducting activities without a valid permit or while the permit is suspended is prohibited (Article 8-2(1)); therefore, during any suspension period, all ride-sharing activity is unlawful.
• The police may draw up a protocol for Road Traffic Rules violations due to technical defects (e.g., a non-functioning light), although, as the head of Kaunas traffic police noted, such defects are not grounds for removing a vehicle from traffic.
• The LTSA plans to intensify physical roadside checks and, together with the police, organise joint raids, verifying documents and insurance, which costs a ride-sharing driver EUR 300–600, compared with approximately EUR 90 for an ordinary driver.
• The Administration seeks to integrate information systems so as to automatically receive data on expired insurance policies and penalties and, where necessary, suspend or revoke permits.

Under Article 27(2) of the Labour Code, it is prohibited to violate the confidentiality of personal correspondence even where the employer is exercising ownership or management rights over electronic communications equipment; therefore, the mere argument that "the subscriber belongs to the company" does not justify the restriction.

An application to the Labour Disputes Commission for damages must be filed within 3 months of becoming aware of the violation, while dismissal and suspension disputes are subject to a 1-month time limit.

Core issue

The legal position of an employee whose personally used number owned by the employer has been blocked during a workplace conflict is as follows: the employee is entitled to claim non-pecuniary damages and unblocking of the number, while the employer bears the burden of proving that the restriction was justified and proportionate. The essential question is whether the employer's right of management over a company telephone number permits blocking it for an employee on sick leave where the number was also used for personal purposes. This question will be resolved under Article 27 of the Labour Code (protection of privacy and confidentiality of personal correspondence), Article 24 of the Labour Code (good faith and the prohibition of abuse of rights), Article 151 of the Labour Code (compensation for damage), and Article 6.250 of the Civil Code (non-pecuniary damage).

Legal assessment

Under Article 27(1) of the Labour Code, the employer must respect the employee's right to private life, and Article 27(2) prohibits violating the confidentiality of personal correspondence even where the employer is exercising ownership or management rights over electronic communications equipment. The following circumstances are relevant in assessing lawfulness:

• whether the number was used personally before employment, and whether the employer knew of and permitted such use;
• what usage and restriction rules were in force and whether the employee was aware of them;
• the purpose, duration, and impact of the measure on the individual.

Article 24(4) of the Labour Code permits employer-owned equipment to be used for other purposes only by agreement on the conditions and procedure, while Article 24(1) prohibits abuse of rights — therefore, consent to transfer the number for administration does not constitute consent to lose personal communications during a conflict. Incapacity for work does not in itself justify blocking; where the measure is applied to only one employee, under Article 26(5) of the Labour Code the employer bears the burden of proving that there was no discrimination on grounds of health condition or exercise of Labour Code rights. Case law confirms this assessment framework: in its judgment of 18 January 2024 in case No. e2A-78-861/2024, the Vilnius Regional Court assessed the disconnection of a work email account together with the employee's isolation and other actions, while in cases before the Supreme Court of Lithuania, non-pecuniary damages of between EUR 1,200 and EUR 5,000 have been awarded for similar privacy violations. To establish liability for damages, unlawful conduct, damage, causation, and fault must be shown (Article 151 of the Labour Code, Article 6.250 of the Civil Code); a new diagnosis is not the sole basis for non-pecuniary damage — the impact of depriving the person of means of communication is also assessed.

Consequences

In practical terms, the employee should:

• demand in writing that the employer specify the basis, scope, and duration of the restriction and the person who made the decision (Article 25(2) of the Labour Code requires written form);
• preserve agreements concerning the number, notifications from the operator, screenshots, requests, and responses;
• document the specific consequences — who could not reach the employee, for how long, and which contacts were disrupted.

A dispute over rights is heard by the Labour Disputes Commission or a court under Article 216(1) of the Labour Code; the Commission may order the restoration of rights and award pecuniary or non-pecuniary damages under Article 217(1) of the Labour Code, and proceedings before the Commission are free of charge, with litigation costs not recoverable (Article 217(3)). The subsequent restoration of communication does not in itself compensate for damage already suffered, so missing the deadline effectively means losing the claim.

Under Article 148(1) of the LAPL, the LVAT's ruling enters into force on the day of its adoption and is not subject to cassation appeal; accordingly, the enforcement of the Minister's order continues until the case is resolved on the merits.

The LVAT found that the LPS failed to substantiate a real risk of irreparable harm if the enforcement of the order were not stayed.

Core issue

For the Lithuanian Prison Service, this decision of the Supreme Administrative Court of Lithuania (LVAT) of 14 October means that Minister R. Tamašunienė's July order suspending the restructuring of Kaunas Prison remains in force and must be complied with, as the court dismissed the separate appeal seeking a stay of its enforcement. The only remaining avenue for the LPS is the principal administrative case before the Regional Administrative Court, in which the Minister's order itself is being challenged. The precise legal question is whether the Minister's order obliging the head of the Service to rescind the decisions on the abolition of positions was adopted lawfully; it will be determined under Article 23 of the Law on Administrative Proceedings of the Republic of Lithuania (LAPL). A dispute between public administration entities that are not subordinate to one another falls, under Article 2(1) of the LAPL, within the category of administrative disputes.

Legal assessment

The LPS filed a complaint with the Regional Administrative Court that met the requirements of Article 23(1) of the LAPL; the application was accepted for hearing in August. The Regional Administrative Court refused the application, and the LVAT, having examined the appeal under Article 144(1) of the LAPL, left the ruling unchanged. The LVAT's key finding was that the LPS failed to substantiate a real risk of irreparable harm if the enforcement of the order were not stayed; the court also assessed the LPS's argument concerning a possible disciplinary sanction against the head, M. Kairys, and reputational damage, and found it insufficient. As regards the sanction against M. Kairys himself — the Minister proposed a reprimand, the Government endorsed it, and the head indicated that he would appeal the decision to court; such a dispute over the imposition of disciplinary sanctions falls, under Article 2(3) of the LAPL, within the category of service disputes.

Consequences

The practical consequences fall along several parallel lines:

• The Minister's order is being enforced: the head of the LPS must rescind the decisions on the abolition of positions at Kaunas Prison, otherwise there is a risk of repeated non-compliance.
• M. Kairys may be issued a reprimand; his appeal against the sanction will proceed under a separate administrative (service dispute) procedure.
• The principal case concerning the lawfulness of the order continues to be heard on the merits before the Regional Administrative Court; only its judgment will be able to annul or uphold the Minister's act.
• If the sanction is imposed, it will constitute yet another challengeable individual act, for which pre-trial review before the Lithuanian Commission for Administrative Disputes is also available under Article 5 of the Law on the Procedure for the Pre-trial Examination of Administrative Disputes.
• The previously imposed sanctions and the rapporteur status, which precludes dismissal from office, form part of the context but do not in themselves determine the outcome of the case.

Since the incident occurred at an event held in a public place (a football match), a ban on attending events held in public places for a period of six months to two years may be imposed under Article 481(4) of the ANK.

If it is established that the act committed entails criminal liability, administrative proceedings do not take place (Article 5(2) of the ANK) — this is determined by a pre-trial investigation under Article 284 of the BK.

Core issue

The conflict that broke out at the Alytus stadium after the match — entering the pitch, chasing, and a physical assault — must be assessed legally, first and foremost, as a violation of public order rather than a matter of football discipline. Accordingly, the fans and the Dainava goalkeeper may be held administratively liable under Article 481 of the Code of Administrative Offences (ANK), or, where the conduct was outrageous, involved threats, or constituted malicious harassment, criminally liable under Article 284 of the Criminal Code (BK).

Legal assessment

Under Article 2(3) of the ANK, only a culpable person whose conduct meets the established elements may be held liable, and under Article 2(7) of the ANK, liability arises only upon the entry into force of the decision. Specific assessment:

• The fans who ran onto the pitch and chased the goalkeeper may be proceeded against under Article 481(1) of the ANK.
• The Dainava goalkeeper, having assaulted the visiting goalkeeper, would be liable under the same Article 481; if his conduct is to be regarded as outrageous behaviour or malicious harassment, Article 284 of the BK applies, with a penalty of up to two years' imprisonment.
• Article 12 of the ANK allows an officer to issue a verbal warning without initiating proceedings; however, this provision applies only to the norms exhaustively enumerated in the Code — Article 481 is not included in that list — so the verbal warning route is available here only after assessing whether the conduct at all satisfies the elements of an offence under Article 5(1) of the ANK.
• The goalkeeper's demonstrative celebration in front of the fans' sector must be assessed separately: on its own, absent offensive provocation or deliberate acts, it may not constitute the offence under Article 481, as there is no intent to breach public order.

Consequences

Since the authority has indicated that a police investigation has not yet been initiated, the first practical step is the officers' decision whether to initiate administrative offence proceedings or a pre-trial investigation under Article 284 of the BK. For the fans, the realistically most severe consequence is the ban on attending events of up to two years provided for in Article 481(4), which would alter their ability to attend Dainava matches. For the club, the incident may carry consequences only under LFF disciplinary procedures, but these are not among the sources provided and are therefore not analysed. The funding issues raised in the fans' statement receive no legal assessment on the basis of the sources provided — they remain a matter of public policy, not of law.