2026: six elections, two kinds of oath and a dispute over who may sit

Level of detail: Basics4 min read

Where 2026 began

Poland's Constitutional Tribunal (TK) checks whether laws comply with the Constitution. Its 15 judges are elected for nine years by the Sejm, the main chamber of parliament.

On 1 January 2026 nine people sat and six seats were empty, so the full bench of at least 11 needed for major cases was impossible.

Bogdan Święczkowski was the Tribunal's President; Karol Nawrocki has been head of state since August 2025, and Donald Tusk heads the government. In 2021 the European Court of Human Rights (ECtHR) ruled that a Tribunal bench including someone elected to a seat the Tribunal had held filled in 2015 was not a tribunal established by law. In 2025 the EU Court of Justice (CJEU) ruled that, partly for this reason, the Tribunal is not an independent and impartial tribunal established by law. In 2021 the Tribunal ruled that the ECtHR may not assess its judges' election; it also rejects the CJEU's jurisdiction.

Six elections on 13 March

On 13 March 2026 the Sejm elected six people: Magdalena Bentkowska, Marcin Dziurda, Anna Korwin-Piotrowska, Krystian Markiewicz, Dariusz Szostek and Maciej Taborowski, all nominated by the Presidium of the Sejm (the speaker and deputy speakers). The resolutions do not assign seats.

The President's Chancellery and Konfederacja politicians said the Sejm broke its rules: it missed the nomination deadline, cut the pre-vote period without a vote and did not present one candidate. The Chancellery of the Sejm said all were presented and the period was shortened without objection, as before. No court has ruled on the elections' validity.

Two kinds of oath

The law says an elected judge swears "before the President". The oath starts the judge's service relationship, a kind of employment; the Tribunal's President then assigns cases (admission to adjudication).

On 1 April 2026 the President swore in only Szostek and Bentkowska; he set the other four no date and did not answer their letters. His Chancellery argued that only two seats fell vacant in his term and 11 judges suffice for a full bench, and accused the Sejm of serious procedural failings over the four. The Chancellery of the Sejm replied that all six are equally placed and the President may not assess the Sejm's choice. The President later said he never refused and it is up to the Tribunal.

On 9 April all six swore in the Sejm, the four new ones addressing the President, who declined the invitation. The Sejm and government accept the oath; the President and the Tribunal's President do not. The President's competence dispute with the Sejm over this oath (Kpt 1/26) is pending.

Who may sit

Święczkowski did not admit the four. On 5 May the ECtHR ordered an interim measure: Polish authorities must not hinder them in taking up and exercising their duties. Justice Minister Waldemar Żurek called it immediately enforceable; the Tribunal's spokesperson said the ECtHR lacks competence.

On 12 May, in K 3/26, the Tribunal held unconstitutional the statute read as obliging the President to swear in those elected by the Sejm. Five judges sat, presided over by Święczkowski, including two persons elected to seats held filled in K 34/15; two dissented. The government does not treat the judgment as binding. In K 34/15 (2015) the Tribunal had held a similar provision constitutional only as a duty to receive the oath without delay.

Two more were later elected, to seats whose terms had ended. Sławomir Patyra, elected 11 June, was sworn in by the President on 28 July, after writing to him twice and an appeal by the Speaker; he will not adjudicate until the four can sit. The President's Chancellery did not invite Maciej Berek, questioning proof of his experience; he swore in the Sejm.

In October the Venice Commission, an advisory Council of Europe body, said in a non-binding opinion that the President should receive the oath without delay and may not review the election; if he refuses or delays, the oath should be possible without him.

Why it matters

The Tribunal's judgments concern laws that bind every citizen, and the government has not published them since 2024. Now state bodies also disagree on who is a judge – like two attendance lists for one room.

On 31 October the Sejm and government count the five sworn only in the Sejm as judges; the President and the Tribunal's President count 10.

Level of detail: For followers11 min read

Starting point: 1 January 2026

On 1 January 2026 the Constitutional Tribunal had nine members whose oath the President had received, including President of the Tribunal Bogdan Święczkowski, Vice-President Bartłomiej Sochański, Justyn Piskorski and Jarosław Wyrembak.¹ Piskorski and Wyrembak were elected in 2017 and 2018 to seats that the Tribunal (K 34/15) held to have been filled in October 2015; a Sejm resolution of 6 March 2024 says they are not judges.^1,2,3

Six seats fell vacant between 3 December 2024 and 20 December 2025, the last two after Krystyna Pawłowicz and Michał Warciński (5 and 20 December 2025).^4,5 A full bench needs at least 11 judges (Art. 37(2) of the Organisation Act), so it was out of reach.^6,7

The Sejm's resolution on the Tribunal (M.P. 2026 item 299)

On 13 March (12 March in some materials), by 235 votes to 197, the Sejm adopted a resolution on the steps needed for the Tribunal to meet the standard of an independent and impartial court established by law (Monitor Polski, the official gazette: M.P. 2026 item 299).^8,2,9,1 The draft came from KO, Lewica, PSL-TD, Centrum and Polska 2050 MPs; PiS and Konfederacja, among others, voted against.^2,1

According to portalsamorzadowy.pl, the Sejm stated that the Tribunal "has ceased to perform its function as an impartial and independent body".²

Six elections on 13 March 2026

Marshal of the Sejm Włodzimierz Czarzasty set a nomination deadline of 11 March; candidates may be nominated by the Presidium of the Sejm or by at least 50 MPs.^10,11,6 The Marshal proposed shortening the seven-day period in Art. 30(4) of the Standing Orders and, hearing no objection ("I hear no objection"), declared it adopted.¹²

All six were nominated by the Presidium; results according to OKO.press:^13,9,1

PiS-nominated Michał Skwarzyński (KUL) received 172 for and 253 against; Artur Kotowski (UKSW), also PiS-nominated, was rejected too.^9,10,6 The resolutions do not say which seat (whose predecessor's) each person fills.⁵ PiS MP Marcin Warchoł called the election "an assault on the Tribunal"; Marshal Czarzasty said an independent Tribunal is independent.¹

Procedural objections and answers

Head of the President's Chancellery Zbigniew Bogucki (16 and 17 March) and K. Bosak of Konfederacja (16 March) said the Sejm had missed the nomination deadline, had not kept the seven-day period (the vote came after two days) and had not presented one candidate to MPs.¹²

The Chancellery of the Sejm replied on 3 April that all candidates had been presented and discussed and that the seven days were waived without objection, as in earlier terms.¹⁴ As precedents it cited several judges elected on one day (2001, 2006, 2010, 2015), Jakub Stelina's same-day nomination and election (2019) and Święczkowski's election in 2022, about 200 days after his predecessor's term ended, without objection from the President.¹⁴

The oath before the President, 1 April 2026

On 18 March Marshal Czarzasty asked the President to act "without delay to enable" the six to take up their mandate.¹⁵

On 31 March the President's Chancellery invited only Szostek and Bentkowska; on 1 April the President received their oath at the Presidential Palace; the other four wrote to him on 26 March, 1 April and 7 April without reply.^16,17,18,19

Bogucki said that "two vacancies arose during President Karol Nawrocki's term" and that 11 judges suffice for a full bench.^20,16,5 On the four, he said their situation was being analysed over serious procedural failings by the Sejm and that an oath in another form would be a constitutional delict.^20,13

The Chancellery of the Sejm replied that all six were validly elected and are "in an identical legal situation"; the President has no power to assess the election, and the two-vacancies argument has no legal basis.^14,21 Bentkowska said the President "cannot censor the Sejm's choice".^5,16 On 17 April the President told Kanał Zero that he had never refused the oath and that the matter depended on the Tribunal; he called those sworn in the Sejm "hotheads".^19,22

The oath in the Sejm, 9 April 2026

On 9 April, in the Sejm's Column Hall, six people took the oath: Markiewicz, Korwin-Piotrowska, Taborowski and Dziurda for the first time, Bentkowska and Szostek again.^23,24,25 The invited President did not attend; the Marshals of the Sejm and Senate and four former Presidents of the Tribunal did.²³ First-time swearers addressed the President and swore before him.²³

A notary drew up a record of the ceremony; the signed oath texts, with notarised signatures, were filed at the President's Chancellery that day with a notarial certificate of delivery.^25,19,23 On 10 April the four asked Święczkowski to let them start work.¹⁹

The National Council of Notaries stated that a notarial record documents events but does not produce their legal effects.²⁵ Bogucki called the ceremony a "grotesque farce"; Markiewicz said the oath is the President's duty "not towards us, but towards the nation".^26,23

Święczkowski assigned offices and cases only to Szostek and Bentkowska; for the four, he held that he could not establish a service relationship until the President confirmed that the act in the Sejm was an oath within the meaning of the Act.¹⁹ On 12 May he said the President should as a rule receive oaths, but extraordinary situations may arise.²⁷

The prosecutors' investigation

The National Prosecutor's Office opened an investigation on 21 April and announced it on 22 April.²⁸ It concerns aiding the President's failure to perform duties by not receiving the oath (Art. 18 § 3 with Art. 231 § 1 of the Criminal Code) and failure to perform duties by Tribunal officials (Arts. 231 § 1 and 218 § 1a).²⁸ Bentkowska and Szostek filed the complaint. No court has ruled on this.²⁸

Competence dispute Kpt 1/26

In late April the President asked the Tribunal to resolve a competence dispute with the Sejm (Kpt 1/26).^29,30 According to Gazeta Prawna, he asks it to declare that the Sejm may not organise acts replacing the personal oath before the President and that the acts of 9 April had no legal effect; powers, he argues, cannot be presumed, and a notarial record confers no effect.²⁹

On 13 May Szostek and Bentkowska declined to sit in the case, calling the bench and the choice of rapporteur defective.³¹ On 23 October the five sworn in the Sejm said the dispute "does not exist" and cannot be decided without at least 11 judges.³² The materials record no decision.³³

ECtHR interim measure: Dziurda and Others v. Poland

On 5 May, in Dziurda and Others v. Poland (application no. 17392/26), the ECtHR ordered an interim measure: Poland must ensure that the competent authorities do not hinder the four from taking up and exercising their judicial duties.^34,35,30

Prime Minister Tusk said the state must remove the obstacles and Minister Żurek that the measure is immediately enforceable; Bogucki said only the Tribunal can assess the dispute and everything is on hold until it hears the President's application.³⁰ Tribunal spokesperson W. Ścibor said the ECtHR has no competence over Poland's constitutional system and the Tribunal had received no formal notification.³⁰

Judgment K 3/26 and decision K 7/26

On 12 May 2026, on an application by PiS MPs represented by Marcin Warchoł, the Tribunal ruled in K 3/26 that Art. 4(1) of the Status Act, read as obliging the President to receive the oath of a person elected by the Sejm, is unconstitutional, and discontinued the rest.^36,31 The bench: Święczkowski (presiding), Sochański (rapporteur), Piskorski, Wojciechowski and Wyrembak; Wojciechowski and Wyrembak dissented, the first writing that the Tribunal had made the President a participant in the election, the second that it set a dangerous precedent.³⁶ According to Notes from Poland, the rapporteur said the oath requires physical presence.²⁷

The bench is disputed: it included Piskorski and Wyrembak, whom the Sejm does not recognise as judges and whom the Supreme Administrative Court named in 2022 in calling the Tribunal "infected with unlawfulness".^2,37 The government does not treat the judgment as binding: Minister Żurek called the case "a political set-up involving doubles" and said there is no judgment; government spokesman A. Szłapka said the Sejm elects the judges.²⁷

The same day, in K 7/26, the Tribunal provisionally barred the Sejm from electing judge-members of the National Council of the Judiciary; the European Commission noted that the bench included a judge appointed in 2017 to an occupied seat, which raises an Article 6 ECHR problem.³⁴

Sławomir Patyra

Zielonacki's term ended on 28 June. On 11 June the Sejm elected Dr hab. Sławomir Patyra (UMCS), nominated by KO, PSL-TD, Lewica and Centrum MPs, by 235 votes to 184 with 5 abstentions; PiS-nominated Artur Kotowski received 173 votes.^38,39

In early July Patyra wrote twice to the President asking for a date, and Marshal Czarzasty called for action without delay.^40,41 On 22 July Bogucki announced an oath for 28 July, saying "the only oath that can be effectively taken is taken before the President".^40,41 On 28 July Patyra took the oath at the Presidential Palace and said he would neither adjudicate nor take part in organisational matters while the four were excluded, calling this "a disastrous excess".⁴²

Maciej Berek

On 4 September the Sejm elected Maciej Berek, nominated by KO MPs, to Piskorski's seat (term ending 18 September): with 437 voting and an absolute majority of 219, he received 226 votes and PiS-nominated Artur Kotowski 184.⁴³ From December 2023 to 14 August 2026 Berek was a minister in the Council of Ministers.^43,44

Bogucki questioned how Berek's ten years as a legal adviser had been verified; Berek said he had provided the documents; the President's spokesman, that the oath would follow once they were provided.^43,45,46

On 14 October Berek took the oath in the Sejm, addressing the President and saying "Taking the oath is my duty"; according to OKO.press a notary was present and a certified text went to the President's Chancellery.^47,48,49 Święczkowski did not let him adjudicate. In a letter that reached the Tribunal around 26 October, according to Rzeczpospolita, Bogucki said Berek had established no service relationship because "before the President" means in the President's physical presence.⁵⁰

September: charges, disciplinary proceedings, a complaint

On 23 September the National Prosecutor's Office charged the director of the Tribunal's Chancellery and the commander of its security service over the alleged obstruction of the four.⁵¹ According to Notes from Poland both denied the charges, and the Tribunal called them "unlawful". No court has ruled on this.^46,51

On 24 September Święczkowski opened proceedings, described as disciplinary or explanatory, against Szostek, Bentkowska and Patyra over their refusal to adjudicate and to attend the General Assembly of Judges.^52,46 On 28 September Patyra filed a criminal complaint against Święczkowski alleging abuse of power (Art. 231 of the Criminal Code) in assigning benches.⁵³ The materials record no court ruling in any of these matters.^52,53

The Venice Commission and the European Commission

On 9 October the Venice Commission, an advisory Council of Europe body whose opinions are not binding, adopted opinion CDL-AD(2026)031, published on 13 October.^54,45,55 According to TVN24 it found the President's role in the oath ceremonial, though the oath has legal significance; the President should receive it without delay and may not review the election.⁴⁵ If the President refuses or delays, it recommended allowing the oath without his physical presence, keeping the prescribed form, verification and delivery to the President.^45,55

Presidential spokesman Leśkiewicz said the opinion "has no legal force whatsoever"; Minister Żurek said the President has no veto over judges elected by the Sejm.⁵⁵

The 15 seats

* not recognised as judges by the Sejm resolution of 6 March 2024 (an annotation, not a category).²

According to the Sejm and the government, the five in column B are judges of the Tribunal.^14,30 According to the President and the President of the Tribunal, there are 10 judges; five people have no service relationship.^29,50,19

Who claims what

What next

On 30 October Anna Korwin-Piotrowska ordered a one-month "immediate break in official duties" for Święczkowski, which he does not recognise; the article on October 2026 covers this.^60,61

Level of detail: Expert34 min read

Scope and applicable law

This text covers 1 January to 31 October 2026, as of 04:00 CET; the late-October dispute over the Tribunal's leadership is covered in a separate article.¹ Throughout, the Act of 30 November 2016 on the Status of Judges of the Constitutional Tribunal (Dz.U. 2016 item 2073; consolidated text Dz.U. 2018 item 1422, the Status Act) and the Act of 30 November 2016 on the Organisation of the Constitutional Tribunal and the Procedure before It (Dz.U. 2016 item 2072; consolidated text Dz.U. 2019 item 2393, the Organisation Act) were in force; the Tribunal Acts of 13 September 2024 never entered into force after judgment Kp 3/24.^2,3,4 Those Acts provided, among other things, a 14-day deadline for the President to receive the oath and, if he failed to act, an oath before a notary, and classed three people, including Piskorski and Wyrembak, as "persons not entitled to adjudicate".⁵ In Kp 3/24 (29 July 2025), on an 11-member bench that included Piskorski and Wyrembak (dissents: Stelina, Sych, Zielonacki), the Tribunal held the provisions on the time limit and form of the oath incompatible with Art. 7 read with Art. 126(2)–(3) of the Constitution, and the provisions using that concept incompatible with, among others, Art. 194(1).⁴ The only amendment to the Status Act in this period (Dz.U. 2026 item 26) takes effect in that respect on 1 January 2027.^6,7

Political setting: President Karol Nawrocki took office on 6 August 2025; Donald Tusk's KO, PSL, Polska 2050 and Lewica government dates from 13 December 2023, with Waldemar Żurek as Minister of Justice and Prosecutor General since 24 July 2025 and Włodzimierz Czarzasty as Marshal of the Sejm.^8,9,10,11 By 11 June 2026, according to Notes from Poland, the President had vetoed 37 bills; the next Sejm election is due in autumn 2027.^8,12

Provisions the parties invoke:

• Art. 194(1) of the Constitution of 2 April 1997 – 15 judges elected individually by the Sejm for nine years; Art. 194(2) and Art. 144(3)(21) – the President appoints the President and Vice-President of the Tribunal; the Constitution says nothing about an oath of Tribunal judges.¹³
• Art. 4 of the Status Act – a judge elected by the Sejm takes the oath before the President of the Republic (the formula begins "I solemnly swear, in performing the duties entrusted to me as a judge of the Constitutional Tribunal…"); refusing the oath equals renouncing the post.²
• Art. 5 of the Status Act – the service relationship arises upon taking the oath; the President of the Tribunal assigns cases and provides working conditions.²
• Art. 3 of the Status Act – a candidate must meet the requirements for judges of the Supreme Court or the Supreme Administrative Court; the materials do not establish the exact wording of the experience requirement that the President's Chancellery invokes against Berek.²
• Art. 37(1)(1) and (2) of the Organisation Act – competence disputes go to the full bench of at least 11 judges; Art. 38(1) – the President of the Tribunal assigns benches in alphabetical order.³
• Art. 30(3)(1) and (5) and Art. 30(4) of the Standing Orders of the Sejm – nomination deadlines and a seven-day period before the vote, "unless the Sejm decides otherwise"; Art. 43(7) – duties of a committee rapporteur.^14,15,16

1. The position on 1 January 2026

According to OKO.press the Tribunal comprised: Bogdan Święczkowski (President of the Tribunal, term to 16 February 2031), Bartłomiej Sochański (Vice-President, to 9 April 2029), Andrzej Zielonacki (to 28 June 2026), Stanisław Piotrowicz (to 5 December 2028), Wojciech Sych (to 8 May 2028), Jakub Stelina (to 5 December 2028), Rafał Wojciechowski (to 7 January 2029), Justyn Piskorski (to 18 September 2026) and Jarosław Wyrembak (to 30 January 2027).¹⁷ The President of the Republic had received the oath of all nine.¹⁷

Piskorski (elected 15 September 2017) and Wyrembak (26 January 2018) are, under the Sejm resolution of 6 March 2024 (M.P. 2024 item 198), not judges of the Tribunal; OKO.press describes them as elected to seats the Sejm had filled in October 2015, as the Tribunal held in K 34/15.^18,19,17,20

The six vacancies arose between 3 December 2024 and 20 December 2025: Muszyński and Pszczółkowski (3 December 2024), Przyłębska (9 December 2024), Jędrzejewski (28 April 2025), Pawłowicz (5 December 2025) and Warciński (20 December 2025).^21,22 The Chancellery of the Sejm said Marshal Szymon Hołownia had repeatedly set nomination deadlines and that opposition MPs had nominated Marek Ast and Artur Kotowski, who did not win the Sejm's support.¹⁴ With nine members a full bench (Art. 37(2) of the Organisation Act) was out of reach.^23,3

2. Sejm resolution M.P. 2026 item 299

Full title: resolution "on the steps necessary to ensure that the Constitutional Tribunal meets the requirements of a court established by law, independent and impartial" (M.P. 2026 item 299).²⁴ It passed by 235 to 197 with no abstentions; the Sejm had first rejected a PiS motion to reject the draft and a minority motion.^19,25 Against were PiS, Konfederacja, Konfederacja Korony Polskiej (Confederation of the Polish Crown), two MPs of the Demokracja Bezpośrednia group, and M. Jakubiak and P. Matysiak.¹⁷

According to portalsamorzadowy.pl the resolution invokes the case law of the Supreme Court, the Supreme Administrative Court, the ECtHR and the CJEU, deems it necessary to shape the Tribunal's composition to the standard of a court established by law, including by electing judges to vacant seats, and refers to the resolution of 6 March 2024.¹⁹

The materials disagree on the date. portalsamorzadowy.pl and TVN24 describe its adoption on Friday 13 March, the day of the elections; the European Commission report, as read by the researchers, also gives 13 March; the research note on political context gives 12 March, citing OKO.press.^19,25,26,17 A record of the 12 March sitting exists but was not retrieved; the header of M.P. 2026 item 299 would settle it.^27,24 This text uses 13 March as the better documented date (two reports describing the order of votes).^19,25

3. The elections of 13 March 2026

Procedure. Marshal Włodzimierz Czarzasty set 11 March as the deadline for nominations to the six seats (Art. 30(3)(5) of the Standing Orders); the Presidium announced its recommendations on Wednesday 11 March.^16,11,23 The Justice and Human Rights Committee sat for about five hours on 12 March; its opinions on eight candidacies are in Sejm prints nos. 2344–2351.¹⁵ The period in Art. 30(4) was shortened by the Marshal's proposal, deemed adopted absent objection; Marshal Elżbieta Witek had done the same on 21 November 2019; the vote took place on 13 March shortly after 13:30.¹⁵ The Sejm voted separately on eight candidacies (votes nos. 125–132).²⁸

According to OKO.press about 427 MPs voted, and all six were nominated by the governing coalition with the Presidium's recommendation; Markiewicz had chaired the Ministry of Justice's codification commission on the courts and prosecution service and was for many years president of the judges' association Iustitia, Korwin-Piotrowska was president of the Regional Court in Opole and of the association Themis, Taborowski had been deputy to Ombudsman Adam Bodnar, and Dziurda had headed the City of Warsaw's legal office.¹⁷ OKO.press (A. Wójcik) reports that Bentkowska was elected first and Szostek fifth (the seventh candidacy considered) and that PSL and Polska 2050 backed both; party backing is not membership, and the materials contain no evidence of party membership of those elected.²²

The resolutions published in M.P. do not say which seat each person fills, nor does the order of votes settle it.²² At least one election resolution is M.P. 2026 item 301; whom it concerns and the numbers of the others were not established.²⁹ The Chancellery of the Sejm cites Art. 194(1) of the Constitution and Art. 30(3)(1) and (5) and (4) of the Standing Orders as the legal basis; the materials also cite Arts. 2–3 of the Status Act.^14,30

Marcin Warchoł (PiS) called the election "an assault on the Tribunal" and criticised voting in bulk; Czarzasty said an independent Tribunal is independent; Stanisław Biernat, a retired Tribunal judge, said the President does not shape the Tribunal's composition but must enable the elected to take office.¹⁷

4. Procedural objections and answers

Bogucki (press conference on 16 March, Radio Zet on 17 March) and K. Bosak (Konfederacja, RMF FM on 16 March) said that (1) the nomination deadline was missed, (2) the seven days of Art. 30(4) were not observed, as the vote came after two days, and (3) one candidate was not presented to MPs.¹⁵

The Chancellery of the Sejm replied on 3 April that (1) all candidates were presented and discussed, (2) the seven-day period was waived without objection, as in earlier terms, and (3) electing several judges on one day has precedents in 2001, 2006, 2010 and on 2 December 2015 (five), Stelina was nominated and elected on the same day (21 November 2019) and Święczkowski was elected on 8 February 2022, about 200 days after Leon Kieres's term expired (23 July 2021), without objection from the President.¹⁴

No court has ruled on the validity of the 13 March elections; K 3/26 concerned the President's duty, not the Sejm's procedure.³¹

5. The oath before the President, 1 April 2026

Correspondence. On 16 March Bogucki raised procedural doubts, and spokesman Leśkiewicz announced a letter to the Marshal asking for explanations; Bogucki said an oath before another body, such as the National Assembly, would have no legal force.³² On 18 March Czarzasty asked the President to act "without delay to enable" the six to take up their mandate; the resolutions were delivered to the President, but the materials establish neither the delivery date nor the content of Bogucki's letter.³² The four wrote to the President on 26 March, 1 April and 7 April; for almost a month nobody from the President's Chancellery contacted them.³³

Ceremony. On Tuesday 31 March the President's Chancellery invited Szostek and Bentkowska; on Wednesday 1 April the President received their oath at the Presidential Palace, the first oath of new Tribunal judges in over four years.^34,35 A prezydent.pl statement exists, as its title shows; its text was not retrieved.³⁶

The President's Chancellery's rationale. On 1 April Bogucki said that "two vacancies arose during President Karol Nawrocki's term" and that receiving two oaths completes the bench; the four's situation was being analysed because of serious, deliberate procedural failings; the Tribunal's functioning is a higher value, and an oath elsewhere would be a constitutional delict.³⁷ According to Notes from Poland he said 11 judges is the minimum for a full bench, another form of oath has no legal basis, and the President expects the Tribunal's judgments to be published.³⁴ Konkret24 reports that Bogucki cited K 34/15 (each judge's term runs separately).²⁸ The two vacancies are the seats of Pawłowicz (5 December 2025) and Warciński (20 December 2025).²² In a Kanał Zero interview on 17 April the President said he had never refused and that an oath at the Palace depended on the Tribunal's position, expected in May.^33,38 The materials contain no formal act of refusal; the President set no date for the four.³³

Answers. The Chancellery of the Sejm (3 April) called the refusal groundless and said the President was claiming a power he does not have; it called the two-vacancies argument extra-legal, because seats vacated under President Duda could then never be filled.^14,39 Szostek and Bentkowska spoke of all six being in an identical position; Żurek said the Act gives the President no right to choose judges and announced an oath, for example in parliament, with notice to the President.^22,34

6. The oath in the Sejm, 9 April 2026

Proceedings. Marshal Czarzasty opened the ceremony in the Column Hall and handed over the 13 March resolutions; six people took the oath, four of them for the first time.^44,45,46 Present were the Marshals of the Sejm and Senate and former Presidents of the Tribunal Bohdan Zdziennicki, Andrzej Zoll, Marek Safjan and Jerzy Stępień; the invited President did not come.⁴⁴ Those swearing for the first time began by addressing the President of the Republic and swore before the President of the Republic; they then filed written oaths at the President's Chancellery's registry and went to the Tribunal, where they spent about an hour and a half.⁴⁴ A wiadomosci.pro summary saying the oath was taken "before the Marshal" contradicts the other sources.⁴⁶

Documents. According to Prawo.pl the following were drawn up: (1) an oath text signed by each person, with a notarised signature; (2) a notarial record of the public oath, noting the broadcast and the formula before the President; (3) a notarial certificate of delivery of the signed act to the President by filing it at the President's Chancellery on 9 April.³³ On 10 April the four sent Święczkowski requests for immediate admission to work, attaching the notarial certificates.³³ The European Commission report also records the filing of notarised copies at the President's Chancellery that day.²⁶

Positions. Those sworn maintain that they had a constitutional duty to take the oath and reject the idea that they should wait.^33,44 The National Council of Notaries stated that a notarial record documents events but does not produce their effects (Art. 79 of the Law on Notaries) and condemned attacks on notaries.⁴⁶ According to Notes from Poland, Bogucki called the event a "grotesque farce", Maciej Berek, then a minister, said the President had claimed a non-existent power, and PiS suspended MP Krzysztof Szczucki for saying the President must receive the oath of all six or of none.⁴⁷

7. No admission to adjudication

Święczkowski assigned offices and cases only to Szostek and Bentkowska; he refused the four a service relationship until the President confirmed that the act in the Sejm was an oath within the meaning of the Act.³³ According to Gazeta Prawna, Szostek and Bentkowska took up office on 9 April, which differs from the oath date of 1 April as the moment the service relationship arises (Art. 5 of the Status Act).^49,2 According to Notes from Poland, Święczkowski had earlier congratulated all six, and on 9 April described the event in the Sejm as a media spectacle.⁴⁷

Markiewicz resigned his judicial post on 14 April, and Korwin-Piotrowska notified the Ministry of Justice of a change in the status of her judicial post.³³ The materials do not establish whether the four are paid.^33,41 On 12 May Święczkowski said the President should as a rule receive oaths but extraordinary situations may arise, and that the government had not executed more than 70 of the Tribunal's judgments.⁵⁰

8. The National Prosecutor's Office investigation

On 13 April Prosecutor General Żurek ordered a preliminary verification; on 21 April the National Prosecutor's Office opened an investigation, announced on 22 April by the Prosecutor General's spokesperson, prosecutor Anna Adamiak.⁵¹ Subject: (a) aiding the President's failure to perform duties by not receiving the oath of the four elected on 13 March – Art. 18 § 3 with Art. 231 § 1 of the Criminal Code; (b) failure to perform duties by Tribunal officials (working conditions, pay, case assignment, staff formalities) – Art. 231 § 1 and Art. 218 § 1a with Art. 11 § 2.⁵¹ The complainants were Bentkowska and Szostek; no case number was given.⁵¹ Prawo.pl dates the opening to 22 April and reports that Minister Żurek also ordered proceedings concerning the President's advisers.^33,52 No court has ruled on this.⁵¹

9. Competence dispute Kpt 1/26

The President's application (President v. Sejm, more than 20 pages) was filed on a Monday in late April and published by the Tribunal on the Wednesday; the materials do not establish the exact date, and on 6 May Bogucki referred to an application "from April".^49,53 According to Gazeta Prawna, the President asks the Tribunal to declare that the Sejm is not entitled to organise or legitimise acts replacing the statutory personal oath before the President, and that the acts of 9 April had no legal effect for taking office; he argues that the Marshal cannot stand in for the President without an express rule, powers cannot be presumed, and a notarial record confers no effect.^49,54

On 13 May Szostek and Bentkowska declined to sit in Kpt 1/26: in their view a bench without the four is defective and rapporteur Piskorski was appointed contrary to Art. 38(1) (in alphabetical order it was the turn of Zielonacki, Bentkowska and Piotrowicz); they cited Xero Flor and C-448/23 and stated: "A judge of the Tribunal may adjudicate only on properly appointed benches".⁵⁵

On 19 October Święczkowski added a statement by three judges to the Kpt 1/26 file and forwarded it to the disciplinary officer.⁵⁶ On 23 October Berek, Dziurda, Korwin-Piotrowska, Markiewicz and Taborowski stated that no competence dispute exists, because the President has no power over the oath, and that it would in any case require at least 11 judges.⁵⁷ Korwin-Piotrowska's orders of 30 October describe the case as pending before the full bench with rapporteur Piskorski, whose term ended on 18 September; the materials do not establish the current rapporteur or a hearing date.^1,58

10. ECtHR: Dziurda and Others v. Poland (17392/26)

According to the ECtHR press release of 6 May, the Court granted an interim measure on the request of four lawyers elected as Tribunal judges on 13 March and not allowed to take up their duties.⁵⁹ The application number 17392/26 and the decision date of 5 May come from the European Commission report (p. 9, fn. 48) and Polsat News.^26,60 Content: Poland is to ensure that the competent authorities refrain from hindering the applicants in taking up and exercising their judicial duties.⁵³ Information on the bench comes only from a post by Minister Żurek.⁵³

Reactions according to Notes from Poland: Tusk – the ECtHR had ruled unequivocally and the state must remove the obstacles; Żurek – the measure is immediately enforceable; Bogucki – the Constitution is the supreme law, only the Tribunal can assess the dispute, and everything is on hold until the President's application is heard; the Tribunal's spokesperson – the ECtHR has no competence to rule on the constitutional system, and the Tribunal knows of no domestic proceedings in the matter and has had no formal notification.⁵³ The materials record no extension or change of the measure by 31 October.^59,26

11. Judgment K 3/26 and decision K 7/26

Judgment. On 12 May 2026, on an application filed in February by a group of PiS MPs (represented by Marcin Warchoł), the Tribunal ruled that Art. 4(1) of the Status Act, read as obliging the President to receive the oath of a person elected by the Sejm, is unconstitutional; it discontinued the remainder, including Art. 2(2).^31,55 Bench: Święczkowski (presiding), Sochański (rapporteur), Piskorski, Wojciechowski, Wyrembak; dissenting opinions: Wojciechowski and Wyrembak.³¹ According to reports, the Tribunal held that the oath before the President does not derive from the Constitution but the legislature could introduce it; "before" means in physical presence; and "it is also not possible to begin a judge's term … without taking the oath".^61,31

Dissents. Wojciechowski: the Tribunal went beyond the application and, contrary to its own case law, "broadens … the powers of the head of state", making the President a participant in the election.³¹ Wyrembak: the ruling is a precedent that endangers the filling of offices, though, citing K 34/15, he accepted that the President may delay the oath in exceptional circumstances.^31,62

Motions to exclude. According to Prawo.pl of 12 May, the six elected on 13 March asked for Święczkowski, Piskorski and Wyrembak to be excluded; Szostek and Bentkowska's letter of 13 May mentions a motion to exclude Piskorski and Wyrembak.^31,55

The bench. In III OSK 2528/21 (16 November 2022) the Supreme Administrative Court named Muszyński, Piskorski and Wyrembak as elected to occupied seats and called the Tribunal "infected with unlawfulness".⁶³ In Xero Flor v. Poland (7 May 2021) the ECtHR found that a Tribunal bench including a person elected in December 2015 to an occupied seat breached the right to a tribunal established by law (Art. 6(1) ECHR); in C-448/23 (18 December 2025) the CJEU found that the Tribunal does not meet the requirements of an independent and impartial tribunal established by law.^64,65 In K 6/21 (24 November 2021) the Tribunal held Art. 6(1) ECHR unconstitutional, among other things, insofar as it gives the ECtHR power to assess the election of Tribunal judges; in response to C-448/23 the Tribunal stated, according to the European Commission, that the CJEU lacks jurisdiction.^66,26 According to OKO.press the presiding judge, Święczkowski, had earlier been National Prosecutor and head of the Internal Security Agency (ABW, 2006–2007); according to Demagog (based on electoral commission data and Sejm prints), rapporteur Sochański was a PiS member and the party's candidate for mayor of Szczecin in 2018, and Wyrembak, according to a Sejm print, a PiS member since 2010.^67,68

Reactions. Minister Żurek called the case "a political set-up involving doubles" and said there is no judgment; government spokesman A. Szłapka said the Constitution clearly states that the Sejm elects the judges.⁵⁰ The materials do not establish whether the judgment was published in the Journal of Laws (Dz.U.); the European Commission notes that the government does not publish the Tribunal's judgments.²⁶

K 34/15. In its judgment of 3 December 2015 (point 5 of the operative part) the Tribunal held that Art. 21(1) of the 2015 Act, read otherwise than as obliging the President to receive without delay the oath of a judge elected by the Sejm, is incompatible with Art. 194(1) of the Constitution.²⁰ Both sides invoke this judgment: the President's Chancellery for the proposition that each judge's term runs separately, Wyrembak in his dissent in K 3/26 for the view that the President may delay the oath in exceptional circumstances, and the government side for the President's duty.^28,31

K 7/26. The same day the Tribunal (on an application by PiS and the KRS) ordered the Sejm, by interim decision, to refrain from electing judge-members of the KRS by absolute majority pending judgment; the European Commission (p. 6, fn. 20) noted that the bench included a judge appointed in 2017 to an occupied seat, which raises an Article 6 ECHR problem.²⁶

12. Sławomir Patyra

Zielonacki, elected in June 2017 to replace Stanisław Biernat, saw his term end on 28 June 2026; on 13 April Czarzasty announced that the procedure would start within two weeks.^69,60 On 11 June the Sejm elected Dr hab. Sławomir Patyra, head of the Constitutional Law Department at Maria Curie-Skłodowska University's law faculty, nominated by KO, PSL-TD, Lewica and Centrum MPs; the committee backed him by 18 to 15 and the Sejm by 235 votes to 184 with 5 abstentions. The other candidate, Artur Kotowski (PiS, nominated for the seventh time), received 173 for, 245 against and 6 abstentions.⁶⁰ The materials give no print number or M.P. item.⁶⁰

In early July Patyra wrote twice to the President asking for a date; about a week before 22 July Czarzasty called for action without delay.^70,71 On 22 July Bogucki announced on X an oath for 28 July under Art. 4(1) of the Status Act, the same day as the oath of four Supreme Court judges.⁷⁰ According to Notes from Poland, Bogucki said there had been some doubts but the President had dispelled them; in May Patyra had accused the President and the President of the Tribunal of "flagrantly unlawful actions".⁷² The European Commission report (as of before 28 July) said the President had not so far allowed the person elected on 11 June to take the oath.²⁶

On 28 July Patyra, whom Prawo.pl describes as the seventh new judge, took the oath at the Presidential Palace and said that until the four can sit he would neither adjudicate nor take part in organisational matters; he announced a statement refusing to adjudicate.⁷³

13. Maciej Berek

Election. On 4 September 437 MPs voted (absolute majority 219); Berek, nominated by a group of KO MPs, received 226 votes and Artur Kotowski (PiS) 184; the committee gave a positive opinion on Berek and a negative one on Kotowski; Polsat does not give the votes against Berek or abstentions.⁵⁸ According to Notes from Poland, those voting against included four coalition MPs, among them Czarzasty, and 11 coalition MPs did not vote.⁷⁴

Career according to Polsat News: head of the Government Legislation Centre (2007–2015), Secretary of the Council of Ministers (2008–2015), from December 2023 a minister and member of the Council of Ministers and chair of its Standing Committee, head of the deregulation team (from March 2025) and minister overseeing the implementation of government policy (from July 2025); earlier, among other posts, director general of the Ombudsman's office.⁵⁸ He was a member of the government until 14 August 2026; the materials contain no evidence of party membership.^75,58 Tusk said he is "one of the most outstanding Polish practising lawyers" and called his ministerial past a drawback.⁵⁸

Qualification dispute. Bogucki questions how Berek's ten years of practice as a legal adviser were verified (no proof that he actually practised).⁵⁸ Leśkiewicz said the President would receive the oath once documents were provided, and Bogucki that the delay lay with the Sejm; on 24 September Berek said he had provided the documents.^76,77 Prawo.pl reports that the President's Chancellery did not invite him, citing doubts about formal requirements.⁷⁸

The oath of 14 October. At about 9:00 in the Sejm Czarzasty handed Berek the resolution; Berek addressed the President, invoked the Status Act and took the oath, then went to the President's Chancellery, stating that he had sworn in a legally permissible and practically possible form.^79,80 According to OKO.press and RMF24, the Presidium of the Sejm, Senate Marshal Kidawa-Błońska and a notary were present, and a notarised text was delivered to the President's Chancellery.^81,82 That day the President said that taking part in the Sejm ceremony had closed Berek's path to an oath before him and announced questions to the Chancellery of the Sejm about his experience; Tusk said the President was renouncing his constitutional duties.^79,83,82

The President's Chancellery's letter. Święczkowski spoke with Berek, did not admit him to adjudication and said he would ask the President whether he recognises the oath in the Sejm.⁸⁴ According to the Tribunal's spokesperson, quoted by PAP and Rzeczpospolita, a letter from Bogucki arrived on a Monday (most likely 26 October): Berek had not established a service relationship, because "before the President" in Art. 4(1) means the President's physical presence, and an oath in the Sejm before the Marshals of the Sejm and Senate is not such an oath.⁸⁴

14. September: criminal and disciplinary proceedings

Charges of 23 September. According to OKO.press the National Prosecutor's Office charged the director of the Tribunal's Chancellery and the commander of the Tribunal's security service with blocking the work of Markiewicz, Korwin-Piotrowska, Taborowski and Dziurda; the charge against the director concerns failure to perform duties under the Act and the Chancellery's statute; suspension from official duties and a ban on entering the Tribunal were imposed on them.⁸⁵ Notes from Poland gives the legal classification as Art. 231 § 1 and Art. 218 § 3 of the Criminal Code and writes that both denied the charges and that the Tribunal called them "unlawful".⁷⁷ Brussels Signal dates the charges to 24 September.⁸³ No court has ruled on this.^85,77

Proceedings of 24 September. According to OKO.press, Święczkowski, at the request of one of the judges who sat on the Tribunal before 2026, opened proceedings against Szostek, Bentkowska and Patyra into why they refuse to adjudicate and to attend the General Assembly, and whether they reported to prosecutors an offence which, in the requesting judge's view, was not committed; the article gives no legal basis.⁸⁶ Notes from Poland describes them as disciplinary, linked to a boycott of the General Assembly in solidarity with the four.⁷⁷ For comparison: notice of a disciplinary offence is given to the President of the Tribunal (Art. 26 of the Status Act), the disciplinary officer is chosen by lot (Art. 27(1)), and disciplinary courts of three and five Tribunal judges decide (Art. 25).^87,2 The materials contain no ruling of a disciplinary court.⁸⁶

Patyra's complaint. On 28 September Patyra filed a complaint with the National Prosecutor's Office alleging abuse of power by Święczkowski (Art. 231 of the Criminal Code) in assigning benches from January to September 2026 without following the alphabetical order of Art. 38(1) of the Organisation Act.⁸⁸ The materials record no prosecutorial decision and no court ruling.⁸⁸

Background. An earlier request by the Prosecutor General for consent to prosecute Święczkowski was refused by the Tribunal's General Assembly around 15 October 2025; the article on 2023–2025 covers it.⁸⁹

15. The Venice Commission: CDL-AD(2026)031

The document. "Poland – Opinion on the powers of the President in the context of the oath-taking of the judges of the Constitutional Tribunal and of other judicial appointments", CDL-AD(2026)031, Strasbourg, 13 October 2026; the number, title and date come from metadata, and the PDF text was not retrieved.^90,91,92 According to the press it is Opinion No. 1294/2026, requested by the Monitoring Committee of the Parliamentary Assembly of the Council of Europe and adopted at a plenary session in Venice on Friday 9 October.^76,93,94 The Venice Commission is an advisory body; its opinions are not binding.⁹³

Content as reported. TVN24: the President's role in the oath is ceremonial, although the oath has legal significance and the President's presence makes it an institutional ceremony (para. 62); the President should receive the oath without delay and not claim a right to review the election; recommendation (para. 98): apply the oath provisions according to their purpose and, if the President refuses or delays, allow the oath without his physical presence, keeping the prescribed form, proper verification and delivery to the President; for other judicial appointments, safeguards against arbitrariness including judicial review (para. 92).⁷⁶ Interia: an oath before the President does not mean a power to examine the grounds of the election, and the procedure may not give the President a role in the election that the Constitution does not provide.⁹³ OKO.press: where a refusal is contrary to law, the judges may complete the formalities without the President's physical participation and begin adjudicating.⁹⁵

Reactions. Leśkiewicz: the opinion "has no legal force whatsoever", the President acts on the basis of the Constitution and statutes, and Berek cannot become a judge without meeting a formal requirement; Żurek: the President has no veto over judges elected by the Sejm, and the oath must be taken without undue delay.⁹³ According to TVN24, Czarzasty said "Patience has run out" and Święczkowski that he cannot recognise the four.⁷⁶

16. The European Commission's 2026 Rule of Law Report

SWD(2026) 921 final of 17 July 2026 (Council document ST 11674/26 ADD 22), in its section on the Tribunal (pp. 8–9), records: the non-publication of Tribunal judgments, including that of 25 February 2026 (SK 68/25); the election of seven judges on 13 March and 11 June; the President receiving the oath of two of the six; the oath of the four in the Sejm on 9 April with notarised copies filed at the President's Chancellery that day; the ECtHR measure of 5 May; an increased Tribunal budget for 2026 (Budget Act of 20 January 2026) and the CJEU judgment C-448/23.²⁶ The report assesses "some further progress" and makes no recommendation specific to the Tribunal, recommending that the action plan be continued.²⁶

17. The seats in 2026

* people whom the Sejm resolution of 6 March 2024 deems not to be judges of the Tribunal; from 19 September one such person (Wyrembak) remains in column A.^19,17

According to the Sejm and the government, the five in column B are judges of the Tribunal "in an identical legal situation", and the government regards the ECtHR measure as binding.^14,53 According to the President and the President of the Tribunal, there are 10 judges and five people who have not established a service relationship.^49,84,33 The number actually adjudicating is lower than column A, since Szostek, Bentkowska and Patyra refuse to sit on the current benches.^55,73

18. Into October

According to RMF24, protests had gone on outside the Tribunal for more than ten days before 15 October, and on 14 October Berek entered the Tribunal under police protection.⁸² On 30 October Anna Korwin-Piotrowska, who maintains that she directs the Tribunal's work under Art. 12(4) read with Art. 11(2) of the Organisation Act, issued orders imposing an immediate break in official duties on Święczkowski and Sochański for one month (Art. 130 of the Law on the System of Common Courts); neither recognises them.^1,97,98 The article on October 2026 covers these events.⁹⁹

Disputed points

• Whether breaches of the Standing Orders' deadlines affect the validity of the 13 March elections – the President's Chancellery and Konfederacja say so, Ordo Iuris considers that they raise doubts but do not prove invalidity, and the Chancellery of the Sejm points to practice; no court has ruled.^15,16,14
• Whether the President may receive the oath of only some of those elected – the President's Chancellery points to two vacancies arising during Nawrocki's term and to failings by the Sejm, while the Chancellery of the Sejm and the Venice Commission consider that the President may not review the election.^37,14,76
• What "before the President" means – for K 3/26 and the President's Chancellery, physical presence; for the statement by eight people elected in 2026 (Prawo.pl, around 19 October), the oath before the President is customary and an oath in the Sejm with delivery of a notarial act is valid; the Venice Commission recommended allowing the oath without the President's physical presence if he refuses or delays; Kpt 1/26 is undecided.^31,84,78,76
• The status of K 3/26 – the President of the Tribunal expects it to be executed; the government says there is no judgment because the bench included people elected to seats held filled in K 34/15. In K 34/15 (point 5) the Tribunal held the analogous 2015 provision constitutional only as a duty to receive the oath without delay; Wyrembak, dissenting in K 3/26 and citing K 34/15, accepted that the President may delay the oath in exceptional circumstances.^50,31,20
• The effect of the ECtHR interim measure – the government demands immediate execution; the Tribunal's spokesperson and the President's Chancellery dispute the ECtHR's competence or defer to Kpt 1/26.⁵³
• Who verifies Berek's qualifications – the President's Chancellery points to a lack of proof of practice; the Venice Commission considers that the President may not assess the qualifications of those elected.^58,76
• The refusal of Szostek, Bentkowska and Patyra to adjudicate versus the proceedings opened by the President of the Tribunal, and the charges against Tribunal officials, which the Tribunal calls "unlawful" – no court has ruled in any of these matters.^55,86,77

Evidentiary gaps

• Date of resolution M.P. 2026 item 299: 13 March according to portalsamorzadowy.pl, TVN24 and the European Commission report, 12 March according to the research note on political context; the M.P. header was not read.^19,25,17,24
• M.P. numbers of five of the six resolutions of 13 March and of those of 11 June and 4 September; which of prints nos. 2344–2351 concerns whom; the vote on Kotowski on 13 March; club breakdowns. The research note on legal texts links M.P. 2026 items 300–305 with implementing acts under the Status Act, which was not verified.^29,15,6
• The research note on 2026 flags an error in the OKO.press text as read, which lists Piskorski instead of Pszczółkowski among those leaving in December 2024; Piskorski sat in K 3/26 in May 2026.^22,31
• The text of the prezydent.pl statement of 1 April, Bogucki's letter to the Marshal and the date the resolutions reached the President; the date Szostek and Bentkowska's service relationship began (1 or 9 April); pay of the four.^36,32,49
• Date the investigation opened: 21 April according to the National Prosecutor's Office statement, 22 April according to Prawo.pl (the date of the statement); this text follows the official document.^51,33
• Kpt 1/26: exact filing date, rapporteur after 18 September, hearing date and outcome. The President of the Tribunal's statement of 19 October refers to a statement by three judges, Prawo.pl to one by eight; the materials do not establish whether this is the same document.^49,56,78
• ECtHR: the full decision was not retrieved; 5 May (European Commission, Polsat) versus 6 May (press release); the press release, as read, does not name the rule of the Rules of Court applied; the bench is known only from a minister's post.^59,26,53
• K 3/26: the case number is given by Prawo.pl ("K 3/2026"), Notes from Poland writes "K 323/26", and the research note on legal texts treats the number as unverified; this text uses K 3/26; the full reasons and any publication in Dz.U. are not available.^55,50,31
• Charges of 23 September: 23 September (OKO.press) or 24 September (Brussels Signal); the classification given by Notes from Poland (Art. 218 § 3) differs from the investigation's scope (Art. 218 § 1a); the nature (disciplinary or explanatory) and basis of the proceedings of 24 September.^85,83,77,51
• Berek: the research note on 2026 treats the notary's presence on 14 October as unverified, while the note on October reports it from concordant accounts; the exact date of the President's Chancellery's letter; votes against him; the wording of the experience requirement; whether Piskorski's term ended on 18 or 19 September.^81,84,58
• CDL-AD(2026)031: full text not retrieved, paragraph numbers only via TVN24; the plenary session number (148th according to OKO.press) and the request date (29 June according to OKO.press, while the Commission's Poland page lists a request of 13 March 2026).^90,76,95,100
• European Commission report: as read, a footnote dates an election to 1 April 2026, which is the date of an oath, not an election; its sentence on the person elected on 11 June was overtaken on 28 July.²⁶
• Commissioner for Human Rights: since July 2026 the office has been held by Sylwia Gregorczyk-Abram; the April statements are those of Marcin Wiącek as RPO at the time.^42,40
• Expert views on the two-vacancies argument: the materials gathered contain only critical analyses (Jaraczewski, Wójcik, Konkret24), so the picture of expert opinion is incomplete.^34,22,28