The Korean government has implemented multiple administrative orders since January 3rd of 2022 as an effort to fight off COVID-19 without any physical lockdown. A new system, called the Vaccine Pass, restricts entries of those who have not been vaccinated or those who were last vaccinated 180 days ago. This new system faces extreme criticism that it forces the general public to take additional shots of COVID-19 vaccines, which are proven to have several fatal side-effects. After the announcement of the new Vaccine Pass system, the government now faces multiple litigations by civic organizations that oppose mandatory vaccination. The Korean society now faces a new issue of whether the Vaccine Pass, which implies mandatory vaccination, is constitutional.
On December 31, 2019, WHO’s Country Office in the People’s Republic of China became aware of cases of a ‘viral pneumonia’ in Wuhan, People’s Republic of China (later termed as ‘COVID-19’). In 2 weeks, the first recorded case outside of China was reported in Thailand, and after only 3 months, on March 11, 2020, WHO made an official statement that ‘COVID-19’ can now be characterized as a pandemic.
Since the first outbreak, it only took 8 months for pharmaceutical companies to develop vaccines to fight off COVID-19, and it seemed like the end of the pandemic. However, factors such as variants of COVID-19, cases of breakthrough infections, and low rate of vaccination in some countries due to lack of supply, eventually led to a new era ‘with Corona’.
Like many countries that chose to phase out COVID-19 restrictions, the Korean government chose to implement the ‘Vaccine Pass’; a COVID-19 vaccine and status certificate system. This type of ‘vaccine passport’ first started in EU as an effort to achieve herd immunity. Citizens who wish to enter multi-use facilities need to present the certificate that proves they have been fully vaccinated. According to the Central Disease Control Headquarters, 85.4% received 2nd shot of vaccination, while 49.2% received the 3rd shot.
However, the Korean government now faces a new phase of the pandemic. The Korean government implemented multiple administrative orders since January 3rd of 2022, regarding the Vaccine Pass, which restricts entries of those who have not been vaccinated or those who were last vaccinated 180 days ago. Facilities are required to have customers check QR codes upon entering, and when an unvaccinated person checks-in, the machine makes large alarm noises. Even though there are alternative certificates for those who can’t be vaccinated for medical reasons, the new system faces extreme criticism that it still forces additional shots of vaccine to the general public. After the announcement of the new Vaccine Pass system, the government faced multiple litigations by civic organizations that oppose mandatory vaccination. Now a new issue of the pandemic arises; “Is the Vaccine Pass, which implies mandatory vaccination, constitutional?”
II. Legal Grounds for the Vaccine Pass in Korea
- The Basic Principles of the Constitution when Restricting Basic Rights
Constitution of the Republic of Korea Article 37.2 regulates many of the basic principles to restrict power of the state. “The freedoms and rights of citizens may be restricted by Act only when necessary for national security, the maintenance of law and order or for public welfare. Even when such restriction is imposed, no essential aspect of the freedom or right shall be violated.” (Article 37.2) Article 37.2 is the basic legal grounds when implementing government’s policies that might possibly infringe any basic rights protected by the Constitution. (1) “restricted by Act” means administrative orders that restrict basic rights need legal grounds (the principle of statutory reservation). (2) “only when necessary” means the government power can restrict citizen’s rights only when it’s urgent and the damage should be minimized (the principle of proportionality). (3) “no essential aspect of the freedom or right shall be violated” means that even when there is a need for citizens’ rights to be restricted, the government power cannot violate citizens’ rights to a point where they infringe human dignity.
- The State’s Protection Duty
Basic rights regarding health are the State’s duty to prevent disasters (Constitution Article 34.6), citizens’ right to a healthy and pleasant environment (Constitution Article 35.1), and the State’s duty to protect health of all citizens (Constitution Article 36.3). According to the Framework Act on the Management of Disasters and Safety Article 3.1.b, ‘infectious diseases under the Infectious Disease Control and Prevention Act’ are defined as ‘social accidents’, which means that the public health issue is still relevant to Constitution Article 34.6.
Constitution Article 36.3 emphasizes the duty of the State to protect the health of its citizens and emphasizes that the State should actively implement policies regarding public health. Therefore, the State is obligated to legislate and provide minimum necessary measures to protect citizens from diseases.
- Emergency Law in Times of an Urgent Need
Constitution of the Republic of Korea Article 76.1 and 76.2 are both emergency orders that can be issued by the President without the convocation of the National Assembly. “In time of internal turmoil, external menace, natural calamity or a grave financial or economic crisis, the President may take in respect to them the minimum necessary financial and economic actions or issue orders having the effect of Act, only when it is required to take urgent measures for the maintenance of national security or public peace and order, and there is no time to await the convocation of the National Assembly.” (Article 76.1) “In case of major hostilities affecting national security, the President may issue orders having the effect of Act, only when it is required to preserve the integrity of the nation, and it is impossible to convene the National Assembly.” (Article 76.2)
Emergency orders do not need prior approval from the National Assembly and although it is an administrative order, it has legislative effect of its own without any delegation from the law. This is different from the delegated orders or executive orders, which requires legal delegation to restrict basic rights; therefore, emergency orders can only be issued in an absolute emergency. During the first outbreak of COVID-19, the possibility of emergency orders was first mentioned. However, the executive office and official residence of the President of South Korea (The Blue House) announced on March 3rd, 2020, that they were not considering emergency orders as a measure to secure patient’s beds for Corona virus infections; as it was a dire issue regarding the treatment of Corona virus patients who needed quarantine from other non-infected patients.
The Blue House maintained its position that emergency orders were unnecessary due to the Infectious Disease Control and Prevention Act, and the National Infection Prevention and Control System for the Purpose of Immediate Response to Emerging Infectious Diseases (which was reformed after the mistakes of MERS in 2015). It allows “the heads of local governments” to “designate all medical institutions as infectious disease management institutions to utilize beds and use private facilities as first aid measure”.
- The Underlining Issue of Korea’s Vaccine Pass and Constitutional Rights
The ‘Vaccine Pass’ can be interpreted as a social consensus made by the government and the civic society, as the Korean government chose to fight off the COVID-19 without a physical lockdown. To avoid lockdown, the government had to choose between rights to one’s own body and the State’s duty to protect public health. This kind of effort was effective during the beginning of the crisis: through social distancing and publicizing infectee information, even though Korea had the second largest number of infected patients in early March of 2020 (the first being China), ‘South Korea has been able to maintain new cases at around 10 cases per day in the third week of April, whereas many countries have reached ever higher number of infections.’ Through these mandatory government procedures and administrative orders, Korea has managed to control the number of infections. However, as the pandemic continues for 2 years and the fear of vaccine side effect outgrew the fear of COVID 19 itself, the right to one’s own body and self-determination clashed with the State’s duty to protect the public health.
The main reason regarding the opposition of the Vaccine Pass is that not only does it restrict the right of self-determination, but it also violates the principle of proportionality. The principle of proportionality is violated because the newly implemented vaccine pass system does not allow any exceptions, which can be a great threat to adolescents, pregnant women and those who were not diagnosed with underlying diseases that can be exempted.
This issue regarding constitutional rights is still an ongoing topic, with 6 administrative litigations and 2 constitutional complaints filed but not yet sentenced. Although results of the constitutional complaints or revocation litigations have not yet been sentenced, whether the Vaccine Pass is constitutional can be predicted by evaluating the court’s judgement regarding suspension of execution.
III. How the Korean Society is Responding to the Vaccine Pass
- Implementation of the ‘Vaccine Pass’ Starting January
As a strategy to construct life ‘with Corona’, the Korean government announced its plan to mandate vaccination passports when entering publicly used facilities. According to the Korea Disease Control and Prevention Agency (hereinafter KDCA) on December 26th, 2021, the expiration date for the Vaccine Pass is 180 days, and for those who were vaccinated with their 2nd dose before July 6th and are not yet vaccinated with their 3rd dose, their vaccination certificate will be invalidated after January 3rd of 2022. Moreover, those who scan their invalid or outdated Vaccine Pass will be notified by the machine with large alarm noises. The guidance period was from January 3rd to 9th.
- Litigations Regarding the Vaccine Pass
As of January 14th, 2022, there have been 6 administrative litigations and 2 constitutional complaints. The purpose of administrative litigation act ‘is to relieve citizens from the infringement of their rights or interests by the illegal dispositions of administrative agencies and the exercise or non-exercise of public power, and settle properly disputes over the rights involved in public law or the application of law, through administrative litigation procedures,’ (Administrative Litigation Act Article 1), and therefore the object of the litigation is equal to the constitutional complaint, as its purpose is also to ‘Any person who is infringed his fundamental rights guaranteed by the Constitution due to exercise or non-exercise of the public power, excluding judgment of the court, may request the Constitutional Court an adjudication on constitutional complaint’ (Constitutional Court Act Article 68). The object of the litigation varies by each applicant but is similarly complaining about the infringement of their right to personal liberty and right to pursue happiness. (Out of the 6 administrative litigations, only those with decisions made by the court are listed below.)
(1) The administrative litigation (updated January 14th, 2022)
1) Revocation litigation and suspension of execution regarding the Vaccine Pass for private academies, study rooms and study cafes- Approved
On January 4th of 2022, the court decided to accept the suspension of execution until judgement on the merits of the case (2021아13365). The court commented that “the Constitution Article 11.1 states all citizens shall be equal before the law and that any measure that discriminate specific groups of people without reasonable cause is unconstitutional and illegal” and that “suspending the execution of mandatory Vaccine Pass in these academic facilities is deemed urgent and necessary to prevent irreparable damage.” The court also commented that “the Vaccine Pass infringes the right to receive education and freedom of occupation of those who are unvaccinated but wish to use these facilities” and “they are pressured to be vaccinated which infringes their right to decide for their own body which greatly discriminates specific group of people,” which “is questionable, as it seems to lack reasonable and objective reason to greatly violate their freedom.” The court has supported its decision on the judgement that “unvaccinated users and owners of these facilities are expected to continue their effort to follow disinfection guidelines and therefore the suspension is not expected to have serious effect on public welfare.”
2) Revocation litigation and suspension of execution regarding all Vaccine Pass (by plaintiffs of 1023 civilians)- Approved
On January 14th of 2022, the court decided to accept the suspension of execution until judgement on the merits of the case (2021아13539). As a result, the Vaccine Pass for large supermarkets, 3000㎡ markets, and department stores and Vaccine Pass for those aged 12 to 18 are no longer in effect. The Vaccine Pass needed for those aged over 18 to enter PC cafes, cafes, restaurants, movie theaters, sports facilities etc. is still effective. The court commented that “Vaccine Pass that does not allow exceptions (such as certificate of PCR tested negative) restricts the right to pursue happiness of those who are unvaccinated” and “although the rights of citizens can be restricted when necessary, no essential aspect of the freedom or right shall be violated and the restriction must be within the principles of proportionality.” The court has supported its judgement on the basis that “unvaccinated users and owners of these facilities are expected to continue their effort to follow disinfection guidelines and therefore the suspension is not expected to have serious effect on public welfare.” The court also commented that “suspending execution of mandatory Vaccine Pass needed to enter these academic facilities is deemed urgent and necessary to prevent irreparable damage.” Regarding the Vaccine Pass for juveniles aged 12 to 18, “there seems to be no reasonable evidence to apply Vaccine Pass for adolescents who have low rate of deaths due to COVID-19” and “because the side-effects of the vaccine for adolescents are unclear at this moment, exempting adolescents from mandatory Vaccine Pass is not expected to have serious effect on public welfare.”
After the court’s decision, the Central Disaster and Safety Countermeasure Headquarters announced on January 17th, three days after the court’s decision, that Vaccine Pass for large supermarkets and department stores (also private academies, study rooms/study cafes, libraries, museums, movie theaters) will not be enforced anymore. It is seen as an effort to reduce any confusion regarding the court’s decision, as the court’s decision to suspend execution is effective immediately. Nevertheless, the government plans to appeal.
3) Revocation litigation and suspension of execution regarding correctional facilities- Approved
On January 18th of 2022, the court decided to accept the suspension of execution until judgement on the merits of the case (2022아10088) The court decided that not allowing unvaccinated attorneys to meet with their clients even in shielded reception rooms restricts the detainee’s right to prompt assistance of counsel and attorney’s communication rights of defense counsel. The court commented that “the rights of anyone who is arrested or detained are ensured by both the Constitution and Criminal Procedure Act and are essential to protect human rights and self-protection.” “Not allowing unvaccinated attorneys to meet with their clients even in shielded reception rooms greatly infringes these rights, which leads to violation of the basic principle of proportionality.” Moreover, “there have not been cases where detainees were infected by their attorneys through these meetings in correctional facilities, and unvaccinated attorneys are still required to wear face masks,” and so “there is no reasonable and objective cause to enforce Vaccine Pass for attorneys to enter correctional facilities,” and “suspending of execution of mandatory Vaccine Pass is not expected to have serious effect on public welfare.”
4) Revocation litigation and suspension of execution regarding restaurants, cafes, karaoke, indoor sports facilities, etc. – Denied
On January 28th of 2022, the court denied the suspension of execution until judgement on the merits of the case(2022아10064). The court commented that “these facilities seem essential for daily life, and mandatory Vaccine Pass greatly restricts social and economic activities of unvaccinated citizens,” but made clear that “vaccination decreases the fatality rate when infected” and “the public need to use Vaccine Pass as a temporary measure to control the increasing number of infections of the Omicron variant.” Cafes and restaurants “have much higher possibility of infection due to difficulty in wearing facial masks”, while karaoke, indoor sports facilities, public baths “are also difficult to keep social distance or keep the air flow.” Moreover, “those who are unvaccinated can show their results of PCR tested negative,” so there are alternatives other than being vaccinated. Therefore “suspending execution of mandatory Vaccine Pass to use these facilities is not deemed urgent or necessary to prevent irreparable damage.”
(2) The constitutional complaint
Along with administrative orders, several civic organizations filed for constitutional complaints that their fundamental rights were infringed due to exercise of governmental power. The two complaints that are pending in court are as follows:
1) Constitutionality regarding Vaccine Pass for private academies, study rooms and study cafes
2) Constitutionality regarding all Vaccine Pass
III. How the Global Society is Responding to the Vaccine Pass
1) United States of America
On September 9th, 2021, President Biden announced a broad plan that suggests mandatory vaccination to federal contractors and all employers with 100 or more employees. President Biden’s plan is encompassed in an Executive Order and a White House broader publication entitled “Path Out of the Pandemic – President Biden’s COVID-19 Action Plan”. Since January, the American Administration has taken actions to make vaccination available to the public and made vaccination requirements for the federal government in July. These efforts resulted in over 175 million vaccinated Americans, but still nearly 80 million Americans eligible to vaccination are not yet vaccinated. Therefore, the COVID-19 Action Plan (1) requires all employers with 100+ employees to ensure their workers are vaccinated or tested weekly (2) requires vaccinations for all federal workers and contractors that do business with the federal government (3) requires vaccinations for health care workers at Medicare and Medicaid participating hospitals and other health care settings (4) calls on large entertainment venues to require proof of vaccination or testing for entry (5) requires employers to provide paid time off to get vaccinated.
However, on January 14th, 2022, the US Supreme Court blocked President Biden’s rule requiring workers at large companies to be vaccinated or tested weekly. It was a 6-3 decision, saying that the workplace safety rule for large companies was “too broad to fall under the authority of the Department of Labor’s Occupational Health and Safety Administration to regulate workplace safety,” and “exceeded the Biden administration’s authority”. Moreover, they ruled that “a more limited vaccine mandate could stand for staff at government-funded healthcare facilities.” The mandate would have affected some 84 million workers.
2) United Kingdom
As of January 27th, 2022, ‘face masks’ and ‘COVID passes’ are no longer legally required in any venue in England, and their use has been scaled down in Northern Ireland. This was due to government’s decision to lift Plan B coronavirus measures. Facilities are allowed to choose whether they will require COVID passes from visitors. More than 64% of the English population have been vaccinated with their 3rd dose. Elsewhere in the UK such as Northern Ireland and Scotland, COVID passes were scrapped for indoor venues.
3) European Union
On January 16th, a bill to change ‘health passport’ to ‘vaccine passport’ was passed by the Assemblée nationale, meaning that now unvaccinated citizens cannot use multi-purpose facilities even with certificates proving COVID-19 tested negative. 5 days later, the Conseil constitutionnel, (the Constitutional Court of France) ruled the vaccine pass to be conditionally constitutional. The vaccine pass is constitutional, with the condition that it’s unrequired for political gatherings (due to general election taking place in 3 months and the need to protect freedom of speech). The court commented that ‘protecting public health’ is a constitutional value justified by the public need and therefore can partially restrict the freedom of gathering and right to move. In France, over 90.6% of citizens aged over 12 are vaccinated.
Celle Higher Regional Court (OLG) ruled that those who wish to enter the court can be ordered by the presiding judge to be tested for COVID-19 even if they are vaccinated. The court commented that the judge can make orders for the purpose of securing a safe courtroom, including measures to prevent Corona Virus infections. The court also stated that orders made by the judge did not violate the principle of proportionality: the number of infections in the area is increasing while the number of vaccinated is still low.
IV. Predicting the results of the Constitutionality of Vaccine Pass
The right of self-determination and the State’s duty to protect public health is still in conflict, as many countries that chose mandatory Vaccine Passes are struggling with civic protests. Countries such as France and Germany evaluated that in times of national crisis such as COVID-19, the State’s duty and right to public health outweighs the individual’s right to self-determination.
The plaintiffs who filed the constitutional complaint assert that their rights to be treated equally, to act upon their own will, the right to their own body, the right to privacy, freedom of occupation, and the right to receive education were infringed. However, South Korea’s Vaccine Pass system also has its legal grounds in the Constitution, as the State is required to protect its citizens from harm and ensure public health. The State can restrict citizen’s rights when necessary for maintenance of law and order or for public welfare. Therefore, it’s highly likeable that the Constitutional Court will rule the Vaccine Pass to be constitutional.
However, as in the case of US and some of the administrative litigations, exceptions to those who are not appropriate for mandatory vaccination should be made to assure the principle of proportionality. If the government makes adjustments to allow exceptions to those who are not eligible to vaccination, it will be more likely for the Vaccine Pass to be constitutional.
Vaccination cannot prevent all cases of infections, but throughout the course of history, it has been proven that vaccines are one of the most effective methods to fight off vicious diseases. As the State has its duty to protect health and well-being of its citizens, using mandatory vaccination is a reasonable measure. However, as every citizen’s rights are protected and guaranteed by the Constitution, their rights should not be overlooked or be sacrificed for public welfare. Therefore, the constitutionality of these mandatory vaccination relies on whether the State can properly balance the constitutional duties of the State and the citizens’ constitutional rights.
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