Atteinte aux droits de la personnalité par internet : compétence internationale

Atteinte aux droits de la personnalité par internet : compétence internationale

  • Posted by admin
  • On 2 juillet 2013
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droit-internationalAu titre des chefs de compétence fondés sur l’objet du litige, l’article 5 3) du Règlement n° 44/2001 du 22 décembre 2000 concernant la compétence judiciaire, la reconnaissance et l’exécution des décisions en matière civile et commerciale dispose qu’une personne domiciliée sur le territoire d’un Etat membre peut être assignée, « en matière délictuelle ou quasi délictuelle, devant le tribunal du lieu où le fait dommageable s’est produit ou risque de se produire ». Cette compétence spéciale constitue une exception ou une option par rapport au principe prévu à l’article 2 § 1 de ce Règlement aux termes duquel :  «Sous réserve des dispositions du présent règlement, les personnes domiciliées sur le territoire d’un État membre sont attraites, quelle que soit leur nationalité, devant les juridictions de cet État membre. »

La mise en œuvre de l’article 5 3) pose des difficultés dans l’hypothèse où le dommage subi par une victime est réparti sur plusieurs Etats. Il en va ainsi lorsqu’une personne subit une atteinte à la vie privée sur internet, la publication sur un site pouvant alors être vue non seulement dans l’Etat où se trouve l’émetteur mais virtuellement dans tous les autres pays. Une seule victime, un seul responsable mais plusieurs lieux de préjudices : où la victime doit-elle agir ?Par exemple, un site anglais publie des informations relevant du droit à la vie privée ou des photographies constituant une atteinte au droit à l’image d’une personne. Le site peut être consulté au Royaume-Uni mais aussi en France, en Allemagne, etc.

Saisie afin de se prononcer sur des faits de cette nature, la Cour de Justice a adapté, dans un arrêt du 25 octobre 2011, la solution qu’elle admettait jusqu’alors en cas de dommages répartis sur plusieurs Etats.

Après avoir rappelé que « le lieu où le fait dommageable s’est produit » vise à la fois le lieu de l’évènement causal et celui de la manifestation du dommage, la Cour a décidé que « L’article 5, point 3, du règlement (CE) no 44/2001 du Conseil, du 22 décembre 2000, concernant la compétence judiciaire, la reconnaissance et l’exécution des décisions en matière civile et commerciale, doit être interprété en ce sens que, en cas d’atteinte alléguée aux droits de la personnalité au moyen de contenus mis en ligne sur un site Internet, la personne qui s’estime lésée a la faculté de saisir d’une action en responsabilité, au titre de l’intégralité du dommage causé, soit les juridictions de l’État membre du lieu d’établissement de l’émetteur de ces contenus, soit les juridictions de l’État membre dans lequel se trouve le centre de ses intérêts. Cette personne peut également, en lieu et place d’une action en responsabilité au titre de l’intégralité du dommage causé, introduire son action devant les juridictions de chaque État membre sur le territoire duquel un contenu mis en ligne est accessible ou l’a été. Celles-ci sont compétentes pour connaître du seul dommage causé sur le territoire de l’État membre de la juridiction saisie. »

Cette solution se distingue de celle qui avait été retenue dans l’arrêt Shevill du 7 mars 1995 (CJCE, 7 mars 1995, Shevill e.a., C-68/93) qui était relatif à une publication diffamatoire matérialisée par une diffamation dans des journaux diffusés dans différents Etats membres. Conformément à cette dernière jurisprudence, deux possibilités sont offertes à la victime.

La première possibilité est de regrouper toutes les poursuites. Traditionnellement, il est admis que la victime peut alors demander réparation de l’intégralité du préjudice subi devant une seule juridiction qui est l’une des juridictions de l’État membre du lieu d’établissement de l’éditeur des publications diffamatoires.

La Cour de Justice a choisi d’améliorer un peu le sorte de la victime dans le cas d’une atteinte par la voie d’internet. Elle admet également, dans son arrêt du 25 octobre 2011, la compétence de la juridiction où est situé le centre des intérêts de la victime, ce qui correspond normalement à sa résidence habituelle.

En d’autres termes, la victime pourra, en cas de dommages subis du fait de la diffusion de contenus par internet,  choisir pour présenter une demande de réparation intégrale, entre l’une des juridictions de l’Etat membre de sa résidence habituelle et l’une des juridictions de l’Etat membre du lieu d’établissement de l’émetteur des contenus.

Par exemple, si un éditeur anglais distribue des exemplaires d’un article diffamatoire dans un journal diffusé dans différents Etats membres, la victime française pourra agir pour demander réparation de son entier préjudice devant une juridiction du Royaume-Uni.  Si la diffusion se fait par internet, elle pourra également saisir une juridiction française.

La deuxième possibilité offerte à la victime est de diviser ses poursuites en agissant devant les juridictions des différents Etats sur le territoire desquels un contenu mis en ligne est accessible ou l’a été.   Dans ce cas, la victime française pourra agir devant les juridictions anglaises, françaises, allemandes, etc…

Le choix ne saurait alors être évident.

Certes, la simplicité d’une action unique est indubitable. Si l’action devant une juridiction étrangère n’est pas évidente, plusieurs actions devant diverses juridictions étrangères compliquent considérablement la situation de la victime. Le fait de pouvoir saisir une juridiction de l’Etat membre où elle a sa résidence habituelle est favorable à la victime.

Mais, dès lors que la demande consiste à obtenir réparation du préjudice subi, il convient de s’interroger sur le sort réservé à l’action ou aux différentes actions en réparation. Les droits de la responsabilité ne sont pas unifiés dans l’Union européenne et une différence de droit positifs peut conduire à des réparations de montants différents. Encore faut-il vérifier que la pluralité de saisines conduit bien à une diversité de lois applicables.

En matière de responsabilité civile, l’Union Européenne a adopté le Règlement (CE) n°  864/2007 du Parlement Européen et du Conseil du 11 juillet 2007 sur la loi applicable aux obligations non contractuelles (Rome II ). Il n’est cependant pas de nature à apporter une réponse générale à la question de savoir si, dans le cas d’éléments de responsabilité civile répartis sur plusieurs pays, le droit applicable devant les différentes juridictions sera identique.

Certes, il s’applique dans les différents Etats membres (dès lors que ses conditions d’application sont réunies), ce qui implique que tous les juges devraient normalement aboutir dans les différents Etats à la même loi applicable. Mais il peut conduire à l’application de plusieurs lois, sans que l’une d’entre elles soit nécessairement la loi du juge saisi.

En outre, dans le cas d’atteinte aux droits de la personnalité, il ne s’applique pas puisque son article 1§ 2 g) exclut de son champ d’application « les obligations non contractuelles découlant d’atteintes à la vie privée et aux droits de la personnalité, y compris la diffamation ». Le risque d’une diversité de lois applicables apparaît par voie de conséquence beaucoup plus important dans cette dernière hypothèse.

Finalement, dans un premier temps, la victime aura intérêt à déterminer les différentes juridictions compétentes. Puis, elle devra ensuite analyser les différents droits internationaux privés des Etats concernés, ce qui lui permettra de déterminer la (les) loi (s) applicable(s) à la responsabilité civile envisagée. Enfin, sur la base de cette (ces) loi(s), elle devra estimer son droit à réparation dans les différents Etats.

Forte de ces résultats, elle pourra alors décider en toute opportunité devant quelle(s) juridiction(s) agir.

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