The Bologna Court Ruling: When ‘Good News’ Requires a Second Reading

Part 2 of 4 — The 2026 Italian Citizenship Verdict
← Part 1: What the Courts Are Actually Deciding
→ Part 3: Venezia, Palermo, and the Emerging Evidentiary Standard (forthcoming)

When “Good News” Requires a Second Reading

The first article in this series documented the volume of unfavorable rulings issued by Italian courts between January and April 2026 — courts across seven distinct judicial districts consistently applied the new legal framework, dismissing claims filed after March 27, 2025, on both substantive and procedural grounds.

Against this backdrop, one decision stands out: Judgment No. 3335/26 of April 17, 2026 by the Ordinary Court of Bologna, which some commentators interpreted as opening a path to shield applicants who took preliminary steps prior to the reform. A rigorous reading, however, demonstrates that this ruling is strictly circumscribed and does not establish a broad general precedent.

The Bologna ruling recognizes that applicants who unequivocally demonstrated an intention to apply and encountered insurmountable administrative barriers (such as the structural unavailability of the consular booking portal) may, under specific conditions, benefit from protection. However, the decision emphasizes that each case requires individualized evidentiary assessment, and that an isolated Prenot@mi screenshot without corroborating formal steps is insufficient.

Subsequent decisions from Brescia and a further ruling from Bologna (examined in Part 1) clarify and narrow the perimeter of this doctrine. Courts increasingly require formal proof of application submission rather than mere documented intent.

Conclusion: an isolated favorable ruling does not constitute a consolidated judicial trend. The complete jurisdictional framework must be evaluated before formulating litigation strategies.