KKO:2026:27 — What the Verdict Means for All of Us

The Term No One Mentions

The term "disorder of psychosexual development" comes directly from the WHO's ICD-10 disease classification — it is the official Finnish diagnostic term under category F66. The ICD-10 classification has been in official use in Finland since the beginning of 1996. The F66 category was not removed internationally until 18 years after the pamphlet was published.

As a physician, Räsänen used the official diagnostic language of her time. Why does the media present this term as though it were a contemptuous characterisation devoid of historical context?

A Verdict That Touches Everyone

The news reports the verdict but does not pause to consider what it means for every citizen of Finland. If a Member of Parliament is convicted for speaking aloud the teachings of the Bible, it concerns everyone's right to voice the doctrines and principles of their religion or ideology.

If a text grounded in biblical teaching is a crime, the same logic applies to every holy book, every religious teaching, and every ideological publication that any group of people finds offensive. State judicial power positions itself above religious doctrine, and constitutional freedom of religion becomes conditional.

A 22-Year-Old Text, Judged by Today's Standards

The pamphlet is from 2004. The verdict came in 2026. A text written more than two decades ago was interpreted as a crime by today's standards. This opens the door to anyone's old writings, speeches, or publications being retroactively reassessed in light of changed societal norms.

Two courts and six judges found no crime. The Supreme Court reached a different conclusion by a vote of 3–2.

Self-Defence Became a Crime

The chain of events deserves to be told in full:

2004: Räsänen writes a pamphlet, printed for educational use in limited distribution.

2019: A police investigation begins based on Räsänen's Pride tweet. The investigation expands to include the 2004 pamphlet. Räsänen publishes the pamphlet online so the public can judge for themselves what she is being accused of.

2026: The Supreme Court convicts Räsänen specifically for this online publication. The charge did not concern the original publication in printed form.

In other words, Räsänen's defence against the accusation became the crime itself. She published the text for the sake of transparency, so that citizens could form their own view. Without the criminal charge, she would never have shared the pamphlet more widely. The state created a situation where the defendant's only means of public self-defence led to a conviction.

"Defamation": Subjective Experience as the Basis for a Crime

The core of the verdict is the concept of "defamation" (solvaaminen), which is a constituent element of the crime of incitement. The Supreme Court convicted Räsänen specifically for "making a text defamatory to a group available" by a vote of 3–2. At the same time, the Court unanimously acquitted Räsänen of her 2019 tweet, in which she supported her view with biblical text.

The contradiction speaks volumes. Quoting the Bible is not a crime, but explaining Christian doctrine in one's own words is.

Shaping the Narrative After the Verdict

The media would do well to exercise greater care regarding the statements it broadcasts without scrutiny on this topic.

In a Yle news report, the Prosecutor General misrepresented Räsänen's message by stating that Räsänen had said homosexuality is "some kind of defect in a person." This is a misleading summary. Throughout the entire process, Räsänen has consistently distinguished between the person and the act. Räsänen's lawyer Matti Sankamo highlighted passages from the pamphlet in which Räsänen explicitly writes that every person is of equal worth regardless of sexual orientation.

Sankamo expressed his bewilderment: "This is the first criminal case in Finland in which the defendant is alleged to have incited against a population group in a text where she explicitly urges readers to respect a minority and treat them as equals."

Christian teaching distinguishes between human worth and human acts. The person is valuable; the acts are evaluated separately. "Love the sinner, hate the sin" is not the same as "there is a defect in the person." The prosecutor's summary erases precisely the distinction that is the entire core of the pamphlet.

Likewise, the commentator's claim of "offensive vocabulary" is misleading. The term "disorder of psychosexual development" was the WHO's official diagnostic term in the ICD-10 classification under category F66, in official use in Finland since 1996 and in force internationally until 2022. As a physician, Räsänen used the medical language of her time. The term is presented as though Räsänen deliberately chose offensive wording, when in fact it was professional terminology.

The narrative is being reshaped after the verdict to make it look self-evident. Context is erased, the timeline is bypassed, and the distinction between person and act is wiped away.

Constitutional and International Law Blind Spots

1. The Constitution of Finland

1.1 Freedom of Expression (Section 12)

"Everyone has the freedom of expression. Freedom of expression entails the right to express, disseminate and receive information, opinions and other communications without prior prevention by anyone."

The verdict's blind spot: The Supreme Court's verdict does not concern prior prevention but after-the-fact punishment. However, the Constitution specifically protects the right to express opinions. The conviction targets the expression of a religious opinion in a pamphlet intended for adult readers for educational purposes. Both the District Court and the Court of Appeal found no compelling societal reason to restrict freedom of expression in this case.

Source: The Constitution of Finland 731/1999, Section 12.

1.2 Freedom of Religion (Section 11)

"Everyone has the freedom of religion and conscience. Freedom of religion and conscience entails the right to profess and practise a religion, the right to express one's convictions and the right to be a member or decline to be a member of a religious community."

The verdict's blind spot: Freedom of religion explicitly includes the right to express one's convictions. Räsänen's pamphlet was based on Christian teaching about marriage and sexuality. The Supreme Court's verdict subjects the expression of religious conviction to criminal assessment.

This raises an unavoidable question: if a view on sexual ethics in accordance with Christian doctrine is a crime, does the same logic apply to all religions whose sacred texts contain similar teachings? The Supreme Court explicitly stated in its verdict that freedom of religion protects the practitioners of all religions equally and that the assessment must be the same regardless of which religion's teachings are used to justify the statements.

During the trial, the prosecutor stated that one may quote the Bible, but that Räsänen's interpretation and opinion of the biblical passages are criminal. This places the state in the role of arbiter of religious interpretation — a position that is problematic under Section 11 of the Constitution.

Source: The Constitution of Finland 731/1999, Section 11. KKO:2026:27, paragraph 25. Prosecutor's statement during the trial, as reported by ADF International and Yle.

1.3 The Principle of Legality in Criminal Law (Section 8)

"No one shall be found guilty of a criminal offence or be sentenced to a punishment on the basis of a deed, which has not been determined punishable by an Act at the time of its commission."

The verdict's blind spot: The pamphlet was written in 2004 and originally printed in limited distribution. The charge did not target the original printed publication but its subsequent availability on the internet. This raises two problems:

The temporal problem: The text was written at a time when the terminology used was in line with official medical diagnostics (ICD-10, F66 category). The act is being assessed by 2026 standards.

The foreseeability problem: The principle of legality requires that a person be able to know in advance what constitutes a crime. Six judges across two courts found no crime. The Supreme Court's 3–2 decision demonstrates that the application of the law is not foreseeable even among judges themselves.

Source: The Constitution of Finland 731/1999, Section 8.

1.4 Equality (Section 6)

"No one shall, without an acceptable reason, be treated differently from other persons on the ground of sex, age, origin, language, religion, conviction, opinion, health, disability or other reason that concerns his or her person."

The verdict's blind spot: The equality provision also protects against discrimination based on religion, conviction, and opinion. If expressing a religious conviction leads to a criminal conviction, are persons holding religious convictions being treated differently on the basis of their opinion?

Source: The Constitution of Finland 731/1999, Section 6.

2. European Convention on Human Rights (ECHR)

2.1 Article 9: Freedom of Thought, Conscience and Religion

"Everyone has the right to freedom of thought, conscience and religion; this right includes freedom to change his religion or belief and freedom, either alone or in community with others and in public or private, to manifest his religion or belief, in worship, teaching, practice and observance."

The verdict's blind spot: ECtHR case law requires that restrictions on the practice of religion be prescribed by law, necessary in a democratic society, and proportionate.

The ECtHR has held that a restriction must correspond to a "pressing social need" and that "necessary" does not mean the same as "useful" or "desirable." Two lower courts explicitly found that no such pressing need existed.

Notably, the grounds for restriction under Article 9 are narrower than in other articles: "national security" has been deliberately excluded, underscoring the special weight of religious freedom. The right to teach one's religion is explicitly within the scope of religious freedom. Räsänen's pamphlet was religious teaching by nature.

Source: ECHR, Article 9. ECtHR Guide on Article 9. Biblical Centre of the Chuvash Republic v. Russia, § 58.

2.2 Article 10: Freedom of Expression

"Everyone has the right to freedom of expression. This right shall include freedom to hold opinions and to receive and impart information and ideas without interference by public authority and regardless of frontiers."

The verdict's blind spot: The ECtHR's established case law emphasises that freedom of expression also protects expressions that offend, shock, or disturb. Freedom of expression is not intended to protect only those opinions with which everyone agrees. The ECtHR has specifically emphasised the broader freedom of expression of politicians on matters of public interest.

Finland has received a significant number of adverse judgments from the ECtHR for violations of freedom of expression: 17 judgments by 2012 — an exceptionally high number for a Nordic country.

Source: ECHR, Article 10.

2.3 Article 7: No Punishment Without Law

"No one shall be held guilty of any criminal offence on account of any act or omission which did not constitute a criminal offence under national or international law at the time when it was committed."

The verdict's blind spot: The same foreseeability problem as in Section 8 of the Finnish Constitution, now at the international level. Article 7 specifically protects against retroactive criminal application. When a text was written in 2004, two courts have found it lawful, and the Supreme Court convicts for it in 2026, the question arises: was the act foreseeably punishable at the time it was committed?

Source: ECHR, Article 7.

3. UN International Covenant on Civil and Political Rights (ICCPR)

3.1 Article 18: Freedom of Thought, Conscience and Religion

The UN Human Rights Committee's General Comment No. 22 (1993) emphasises:

Article 18 does not permit any limitations whatsoever on the freedom of thought and conscience or on the freedom to have or adopt a religion.
This freedom is protected unconditionally, and no derogation from it is permitted even in time of public emergency (Article 4.2).
Limitations on the manifestation of religious freedom must be directly related to and proportionate to the specific need on which they are based.
Limitations may not be imposed for discriminatory purposes or applied in a discriminatory manner.

The verdict's blind spot: ICCPR Article 18 explicitly protects religious teaching. Räsänen's pamphlet was religious teaching on the Christian understanding of marriage. The UN Human Rights Committee's interpretation is that this right is fundamental and cannot be derogated from even in a state of emergency.

Source: ICCPR, Article 18. UN Human Rights Committee General Comment No. 22 (1993), paragraphs 1, 3, 8.

3.2 Article 19: Freedom of Opinion and Expression

"Everyone shall have the right to hold opinions without interference."

The verdict's blind spot: Article 19(1) protects the right to hold opinions without any conditions. Räsänen's opinion on the Christian understanding of marriage is a protected opinion.

Source: ICCPR, Article 19.

3.3 Article 20(2): Prohibition of Hate Speech and Its Limits

"Any advocacy of national, racial or religious hatred that constitutes incitement to discrimination, hostility or violence shall be prohibited by law."

The verdict's blind spot: Article 20(2) prohibits specifically advocacy of hatred that constitutes incitement to discrimination, hostility, or violence. The UN Expert Seminar (Geneva 2008) has emphasised that Articles 19 and 20 must be read together in harmony and that Article 20 must not become a negation of Article 19.

Räsänen's pamphlet does not incite violence or discrimination. It presents Christian teaching that explicitly urges respect for all people regardless of sexual orientation.

Source: ICCPR, Article 20. OHCHR Expert Seminar on Articles 19 and 20 of the ICCPR (2008).

4. Structural Blind Spots

4.1 The Right to Be Offended vs. Fundamental Rights

The core of the verdict is the concept of "defamation" (solvaaminen), which is a constituent element of the crime of incitement. This raises a principled question: is the subjective experience of being offended a sufficient basis for restricting a constitutional right?

Both ECtHR and UN Human Rights Committee case law have repeatedly held that freedom of expression also protects expressions experienced as offensive. "Offensiveness" is a subjective experience that varies by time, place, and recipient. Fundamental rights, by contrast, are objective legal norms.

If the experience of being offended is sufficient to criminalise expression, it logically follows that every religion's sacred texts are potentially criminal, as they contain teachings that someone may find offensive; public discourse narrows to what no one finds offensive; and the exercise of fundamental rights becomes conditional on others' subjective experience.

4.2 Retroactive Reinterpretation

The pamphlet was written in 2004. The verdict was delivered in 2026. During this period, medical terminology has changed (ICD-10's F66 category removed in ICD-11 in 2019/2022), societal norms have shifted, and the legislation has not been amended.

The verdict applies present-day norms to a 22-year-old text. This creates a precedent where anyone's decades-old publications, speeches, or writings can be reassessed in light of changed societal norms.

4.3 The Punitive Nature of the Process

ADF International's director Paul Coleman has repeatedly emphasised that the process itself is punishment. Räsänen's legal process has lasted nearly seven years (2019–2026) and has included over 13 hours of police interrogations in which she was repeatedly asked to explain her theological understanding of the Bible. Two courts acquitted her unanimously, and the prosecutor appealed both times. Finland is one of the few countries where a prosecutor can appeal an acquittal all the way to the highest court.

5. Next Step: The European Court of Human Rights

Räsänen has announced that she is seriously considering an appeal to the European Court of Human Rights. ADF International is supporting her defence. The grounds for appeal cover Article 9 (the verdict restricts the right to teach one's religion), Article 10 (the verdict punishes the expression of opinion), Article 7 (the punishability of the act was not foreseeable at the time it was committed), and Article 14 in conjunction with Articles 9 and 10 (differential treatment on the basis of religious conviction).

The ECtHR has previously held that freedom of religion is one of the foundations of a democratic society and has emphasised that the state may not dictate what a person believes.

Summary

The Supreme Court's verdict raises questions that public discourse and the media have not sufficiently addressed:

A) The terminology used was official medical diagnostics at the time of writing (WHO ICD-10, F66).

B) Six judges across two courts found no crime. The Supreme Court majority was 3–2.

C) Sections 11 and 12 of the Constitution explicitly protect freedom of religion and freedom of expression.

D) ECHR Articles 9, 10, and 7 as well as ICCPR Articles 18 and 19 set a high threshold for restricting fundamental rights.

E) The subjective experience of being offended does not, under international case law, constitute a sufficient basis for restricting fundamental rights.

F) A 22-year-old text is convicted on the basis of changed norms, creating a precedent of retroactive reinterpretation.

G) The logic of the verdict applies to all religions and ideologies, not solely to Christianity.

The question is not whether Räsänen's views are right or wrong. The question is whether there is room in a democratic society to express a religious conviction without criminal consequences — and whether the experience of being offended has overridden constitutional freedoms.

Do the people of Finland understand what today's narrow one-vote defeat meant for every one of us — not just for one Member of Parliament?

ICD-10 F66 Terminology Is Still Everywhere: An Investigation

Research conducted 26 March 2026

The Supreme Court deemed the term "disorder of psychosexual development" to be "entirely erroneous in light of modern medicine" and "defamatory." The research below demonstrates that this exact term is currently publicly available in dozens of official, medical, and academic sources — including the official Finnish disease classification maintained by THL, which is used daily in healthcare.

THL Officially Maintains the Exact Same Terminology

Finland's official ICD-10 disease classification still contains the F66 class in its entirety, including all its subcodes. This classification is mandatory for all disease classification in patient records under a decree of the Ministry of Social Affairs and Health (13/332/1995). The classification is maintained by THL and is publicly available in several formats.

THL/Kanta Code Service is the official national code server where the ICD-10 classification can be browsed in full. The F66 code "Psychological and behavioural disorders associated with sexual development and orientation" is listed there with all its subcodes, including F66.8 "Other specified disorders of psychosexual development" and F66.9 "Unspecified disorder of psychosexual development." THL last updated the code server in 2025 (Code Service Bulletin 106/2025), and the F66 codes were not removed.

THL's Julkari archive contains two key publicly available publications: the Psychiatric Classification Handbook (2nd edition, 2012), which includes all F66 diagnoses with full descriptions, and the Disease Classification ICD-10 (3rd Finnish edition, 2011).

Particularly noteworthy is that the official Finnish classification contains the code F66.81 "Other disorder of psychosexual development, homosexual" — a diagnosis that explicitly links homosexuality and disorder of psychosexual development in the same phrase.

Code	Official Finnish Term	Available
F66	Psychological and behavioural disorders associated with sexual development and orientation	Yes
F66.0	Sexual maturation disorder	Yes
F66.1	Ego-dystonic sexual orientation	Yes
F66.2	Sexual relationship disorder	Yes
F66.8	Other specified disorders of psychosexual development	Yes
F66.81	Other disorder of psychosexual development, homosexual	Yes
F66.9	Unspecified disorder of psychosexual development	Yes

Finnish Medical and Academic Sources

Terveysportti's ICD-10 search tool contains all F66 codes and is part of the core healthcare infrastructure. Katariina Parhi's article "Diagnosis: Homosexualitas 320.6" (SQS journal, 1–2/2018) directly states that ICD-10 lists F66 subcategories. Ahjos.net provides a publicly available complete Finnish-language F66 classification with descriptions. ICD-codes.info lists the F66 category in Finnish with all subcodes.

WHO's Own Sources

WHO's official ICD-10 browser still lists all F66 codes. The United States ICD-10-CM uses the F66 code as an active billable diagnosis code in 2026. Geoffrey M. Reed et al.'s article "Disorders related to sexuality and gender identity in the ICD-11" (World Psychiatry, 2016) and Susan D. Cochran et al.'s article "Proposed declassification of disease categories related to sexual orientation in the ICD-11" (Bulletin of the WHO, 2014) use F66 terms extensively. The APA's official position statement refers directly to the F66 category.

LGBTQ Community's Own Sources

Sateenkaarihistoria.fi quotes the Finnish-language definition of the F66.1 diagnosis directly from THL's Psychiatric Classification Handbook and uses the term "disorder of psychosexual development."

Encyclopaedias

The English-language Wikipedia articles Ego-dystonic sexual orientation, Sexual maturation disorder, and Sexual relationship disorder quote WHO's F66 definitions. The Finnish-language Wikipedia article ICD-10 main class F lists the F66 code. EverybodyWiki, MedBox, and Oxford Reference contain equivalent content.

What This Means

The Finnish state convicted a citizen of a crime for using terminology that the Finnish state itself currently keeps officially available and mandatory as part of its healthcare infrastructure. This structural contradiction makes the Supreme Court's reasoning extremely vulnerable at the European Court of Human Rights.