Many French people took the derogatory movement certificate proposed by the Ministry of Interior during the two lockdowns in 2020. However, the need for a move could be justified otherwise, and not exclusively by means of this certificate. This was emphasized by the Council of State in its decision of 22 December 2020.
An individual had challenged the March 23, 2020 decree and sought its annulment directly before the Council of State. By the contested decree, the Prime Minister had prohibited the movement of any person out of his home, subject to exceptions which were exhaustively listed and had to be duly justified. The text specified that persons wishing to benefit from one of these exceptions must carry a .
For the Conseil d’État, the obligation to does not provide for any particular formalism. Therefore, any document providing equivalent justification could be produced for this purpose. For example, a certificate may be written on free paper as long as it specifies the authorized reason for exit. The certificate proposed by the Ministry of Interior is only a model made available for convenience.