461_32 substantive_scope 32. <414> It follows from the facts as established by the domestic courts that the applicants were dismissed because of a strike action. The Court reiterates its findings in the Barış and Others v. Turkey decision (no. 66828/16, 14 December 2021) that strike action is, in principle, protected by Article 11 only in so far as it is initiated by trade-union organisations and considered as being effectively – and not merely presumed to be – part of trade-union activity. The Court has never accepted that a strike that was not called by a trade union but rather by that trade union’s members, or even non-members, was also entitled to the protection of Article 11 (ibid., § 45). The Court would also note in this context that, according to the practice of the European