Bulletins municipaux : quel cadre juridique ?
par Christophe Robert (www.edile.fr)
Supports de communication largement répandus dans les communes, les départements et les régions (un peu moins dans les intercommunalités), les bulletins locaux d’information générale sont soumis à un double encadrement juridique. Ce dernier résulte, d’une part, de la loi du 29 juillet 1881 et, d’autre part, du Code général des collectivités territoriales (CGCT). Des règles qui trouvent également à s’appliquer aux sites Internet publics locaux.
Des bulletins soumis à la loi sur la presse du 29 juillet 1881…
Juridiquement assimilés à des publications diffusées au public, les bulletins locaux sont soumis aux dispositions de la loi du 29 juillet 1881 relative à la liberté de la presse (1). En application de ce texte, le directeur de publication (le plus souvent le maire ou le président de l’exécutif) est présumé être l’auteur principal des crimes et délits commis par voie de presse (injure, diffamation…). Les auteurs des articles litigieux sont, pour leur part, considérés comme complices. Aussi ces dispositions expliquent-elles la nécessaire vigilance dont doivent faire preuve les responsables locaux quant au contenu des articles présentés dans ces publications.
… mais aussi au Code général des collectivités territoriales
La loi reconnaît au profit des élus d’opposition un droit d’expression spécifique sur ces supports. Ainsi, le Code général des collectivités territoriales dispose : « Dans les communes de 3 500 habitants et plus, lorsque la commune diffuse, sous quelque forme que ce soit, un bulletin d’information générale sur les réalisations et la gestion du conseil municipal, un espace est réservé à l’expression des conseillers n’appartenant pas à la majorité municipale. Les modalités d’application de cette disposition sont définies par le règlement intérieur » (2). Toujours applicable à ce jour, cette disposition a cependant été modifiée par la loi NOTRe du 7 août 2015 (lire infra).
Selon la jurisprudence administrative, « toute mise à disposition du public de messages d’information portant sur les réalisations et la gestion du conseil municipal doit être regardée, quelle que soit la forme qu’elle revêt, comme la diffusion d’un bulletin d’information générale » (3). Les termes « sous quelque forme que ce soit » font expressément référence aux éventuels supports numériques, notamment les sites Internet, pour lesquels le droit d’expression des élus d’opposition trouve pleinement à s’appliquer. Le ministère de l’Intérieur a ainsi eu l’occasion de préciser que « si le site internet de la ville offre une diffusion régulière d’informations sur les réalisations et la gestion du conseil municipal, en vertu du droit que leur reconnaît la loi, les conseillers minoritaires doivent y avoir une tribune d’expression » (4).
Dans les communes de 3 500 habitants et plus, la loi reconnaît un droit d’expression au profit des élus d’opposition dans les bulletins d’information générale et les sites web locaux
Quand la jurisprudence précise les règles du jeu
En pratique, le droit d’expression des conseillers d’opposition dans les supports de communication institutionnels constitue un sujet délicat, comme en témoigne la jurisprudence. Sur le plan « politique », la loi impose clairement de veiller à ce qu’un bulletin d’information permette l’expression de toutes les tendances au sein de l’assemblée délibérante (tout du moins dans les villes et les collectivités les plus importantes). En clair, la publication de tribunes mettant en cause la politique locale menée par une majorité fait partie des règles du jeu démocratique que les édiles doivent accepter. Dans ce cadre, la jurisprudence administrative ne reconnaît pas de pouvoir de « censure » au profit du maire s’agissant des tribunes d’expression (5).
Reste qu’en parallèle, sur le plan pénal, un directeur de publication peut voir sa responsabilité engagée en cas de propos délictuels publiés dans un support de communication (6). Aussi, selon la jurisprudence, le maire est-il « en droit de refuser de publier un écrit qu’il estime, sous le contrôle du juge, diffamatoire, injurieux ou discriminatoire ou portant atteinte à l’ordre public et aux bonnes mœurs » (7). Un risque de mise en cause pénale pénale qui ne saurait cependant suffire à être invoqué pour s’opposer à la simple publication de propos contestataires.
Côté propagande électorale, le Conseil d’Etat a eu l’occasion de préciser qu’« une tribune publiée par une élue d’opposition, si elle peut constituer un élément de propagande électorale, ne saurait être considérée comme un don de la commune au sens de l’article L. 52-8 du Code électoral » (8).
Dernière précision, si la loi impose aux communes concernées de réserver un espace d’expression réservé à l’opposition, la jurisprudence considère que rien n’interdit qu’un tel espace soit également réservé au profit des élus de la majorité (9).
Des changements attendus
La loi du 17 mars 2013 (10) ayant abaissé de 3 500 à 1 000 habitants le seuil à partir duquel s’applique la proportionnelle, il semblait logique qu’un texte vienne modifier le Code général des collectivités territoriales afin de rendre obligatoire l’instauration d’un espace d’expression des opposants dès 1 000 habitants. C’est désormais (presque) chose faite depuis la loi NOTRe du 7 août 2015 (11), ce texte modifiant l’article L.2121-27-1 du CGCT en ce sens. Mais cette disposition n’entrera cependant en vigueur qu’à compter du prochain renouvellement des conseils municipaux, autrement dit en 2020. Une obligation qui concernera à l’avenir quelque nouvelles 6 550 communes…
_________________________
Notes
(1) Loi du 29 juillet 1881, voir en particulier les articles 42 et 43
(2) Article L. 2121-27-1 du CGCT, inséré par la loi relative à la démocratie de proximité du 27 février 2002
(3) Cour administrative d’appel de Versailles, 17 avril 2009
(4) Réponse du ministre de l’Intérieur à la Question écrite n° 14395 de M. Jean Louis Masson, JO Sénat (Q) du 16 mars 2006
(5) Cour administrative d’appel de Versailles, 8 mars 2007 ; 27 septembre 2007
(6) Cass. Crim., 22 octobre 2002, n° 01-86908
(7) CAA Nancy, 15 mars 2012, n° 11NC01004
(8) Conseil d’Etat du 7 mai 2012, n° 35353 ; Réponse du ministère de l’Intérieur à la Question écrite n°14446 de Jean Louis Masson, JO Sénat(Q) du 12 mars 2015
(9) Cour administrative d’appel de Marseille, 19 janvier 2012, n° 10MA02058
(10) Loi n° 2013-403 du 17 mai 2013 relative à l’élection des conseillers départementaux, des conseillers municipaux et des conseillers communautaires, et modifiant le calendrier électoral
(11) Article 83 de la loi n° 2015-991 du 7 août 2015 portant nouvelle organisation territoriale de la République, dite loi NOTRe
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