Case Law, Strasbourg: Ion Cârstea v. Romania, Breach of positive obligation to protect the right to reputation – Hugh Tomlinson QC | Inforrm's Blog: "In relation to the question of whether the applicant was a “public figure”, the Court said:
“The role or function of the person concerned and the nature of the activities that form the subject matter of the article constitute another important criterion, which relates to the previous one. In this connection, the Court has previously held that a fundamental distinction needs to be made between reporting factual matters capable of contributing to a debate in a democratic society, such as those relating to politicians in the exercise of their official functions, and reporting details of the private life of an individual who does not exercise such functions, with the sole aim of satisfying public curiosity … In the latter case, freedom of expression calls for a narrower interpretation” 
In the present case the applicant was a university professor unknown to a wider public." 'via Blog this'